TXT FM BP.pdf.pdf

Ref. Ares(2021)2234504 - 31/03/2021
EUROPEAN COMMISSION
DIRECTORATE-GENERAL
JOINT RESEARCH CENTRE
Directorate B – Growth and Innovation
  Circular Economy and Industrial Leadership

Seville, 31 March 2021

Final meeting of the Technical Working Group (TWG)

for the review of the BAT reference document
for the Textiles Industry (TXT BREF)

25 May – 11 June 2021 (tentative)

BACKGROUND PAPER (BP)

Purpose  of  this  background  paper  and  of  the  final  Technical  Working  Group  (TWG)
meeting

The objective of this background paper is to outline the main issues proposed to be discussed at
the  final  meeting  of  the  Technical  Working  Group  for  the  review  of  the  BAT  reference
document  for  ‘the  Textiles  Industry'  (TXT  BREF)  under  the  Industrial  Emissions  Directive
(IED) (2010/75/EU).

The meeting is intended to be held as web-based meeting in the period 25 May to 11 June 2021
with  the  objective  of  agreeing  upon  the  remaining  work  needed  to  finalise  the  review  of  the
TXT BREF. In particular, it is proposed that the TWG meeting focuses on:

I.  agreeing on the draft BAT conclusions and therefore on the actual text in Chapter 5 (and
related items) of the TXT BREF;
II.  agreeing  on  the  main  corresponding  modifications  proposed  for  the  sections  on
'Techniques to consider in the determination of BAT';
III.  identifying  elements  that  should  be  mentioned  in  Chapter  7  of  the  TXT  BREF  (i.e.
Concluding remarks and recommendations for future work);
IV.  agreeing upon the remaining work needed for finalising the BREF review.

This BP includes:

  background information for the final TWG meeting;
  a summary of the main TWG comments received on the first draft of the revised TXT BREF
(published in December 2019) and the EIPPCB assessment of those comments;
  the  proposed  modifications  to  the  draft  TXT  BREF  resulting  from  the  TWG  members'
comments, focusing on the proposed changes to the draft BAT conclusions;
  the proposals to include, when appropriate, in the Concluding remarks and recommendations
for future work chapter of the BREF.

Edificio Expo, C/ Inca Garcilaso, 3 – E-41092 Sevilla, Spain
Telephone: +34-954 488 284. Fax: +34-954 488 426.
E-mail: xxxxxxxxxxxxx@xx.xxxxxx.xx, Internet: http://eippcb.jrc.ec.europa.eu/

link to page 5 Background paper – Final meeting for the review of the TXT BREF
Background information

The  kick-off  meeting  for  the  review  of  the  TXT  BREF  was  held  from  12-15  June  2018   in
Seville, Spain. The data collection process was officially scheduled from  mid-February to end
of-April 2019.

The first draft of the revised TXT BREF was issued on 19 December 2019 and the consultation
period for TWG members ended on 20 March 2020. A total of 1072 comments (750 identified
as major and 322 as minor) were received by the EIPPCB and were made available to the whole
TWG through BATIS. Of these 1072 comments, 639 are addressed in this document, i.e. those
considered to have a bearing on the BAT conclusions.

The  distribution  of  the  comments  received  on  the  first  draft  of  the  revised  TXT  BREF  is
summarised in Table 1.

Table 1:  Distribution of the total number of comments submitted on the first draft of the revised
TXT BREF (version of December 2019)
Comments
BREF Chapter/Section
Percentage
Number
(%)
Whole document
9
0.8
Preface
0
0.0
Scope (BREF)
3
0.3
Chapter 1 – General information
14
1.3
Chapter 2 – Applied processes and techniques
45
4.2
Chapter 3 – Emission and consumption levels
29
2.7
Chapter 4 – Techniques to consider in the determination of
279
26.0
BAT
Chapter 5 – BAT conclusions
639
59.6
Chapter 6 – Emerging techniques
11
1.0
Chapter 7 – Concluding remarks and recommendations for
0
0.0
future work
Chapter 8 – Annex I: Textile auxiliaries
40
3.7
Chapter 9 – Annex II: Dyes and pigments

Chapter 10 – Annex III: Wet Processes: Machinery and
1
0.1
Techniques
Chapter 11 – Annex IV: Typical recipes (with some
0
0.0
associated emission factor) in the textile sector
Chapter 12 – Annex V: Typical pollutants (and potential
0
0.0
sources) in air emissions from textile processes
Chapter 13 – Annex VI: auxiliaries classification tools
0
0.0
Chapter 14 – Advanced oxidation processes (Fenton reaction)
0
0.0
Chapter 15 – Annex VII: Plants having taken part in the data
0
0.0
collection
Chapter 16 – Annex VIII: Wool carpet dyeing
0
0.0
Glossary
2
0.2
References
0
0.0
Total:
1072
100

All the comments received and the accompanying additional information have been assessed by
the EIPPCB and have been used in the preparation of this BP. An updated working draft of the
TXT BREF will be made available to the TWG prior to the final meeting.
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Background paper – Final meeting for the review of the TXT BREF
It is therefore recommended that TWG members print a coloured copy of this revised
draft as it will help them to identify text under discussion at the final TWG meeting.

Before coming to the meeting

As a TWG member, you should read this background paper (BP) and Chapter x before coming
to  the  meeting  to  determine  your  position  on  the  identified  issues.  Final  TWG  meetings  are
characterised  by  deep  technical  discussions  and  represent  the  last  opportunity  for  the TWG  to
discuss the contents of the BREF (and of the BAT conclusions in particular).

Whether  or  not  your  position  differs  from  any  proposal  in  this  BP,  you  should  come  to  the
meeting  prepared  to  justify  your  position  and,  if  you  have  a  different  view,  to  present  an
alternative proposal and the evidential basis for that proposal.

IMPORTANT: Please be advised to bring at least the following documents with you to the
meeting (all of these will be made available  in BATIS) as the EIPPCB will not be able to
provide you with printed copies:

  this background paper;
  the revised proposal for the BAT conclusions (coloured version);
  the first draft of the revised TXT BREF dated December 2019 (coloured version);
  the updated graphs/figures including the emission levels and other environmental
performance levels.

Aim and structure of this background paper

The  aim  of  this  background  paper  is  to  structure  and  enable  efficient  discussions  at  the  final
TWG meeting. Some items relevant to the BAT conclusions are proposed for discussion at the
final TWG meeting (i.e. items under Section 1 of this BP) while other items are proposed to be
discussed only if requested in advance of the meeting (i.e. items listed in Section 2 of this BP).
Items  are  listed  in  Section  2  either  because,  based  on  the  assessment  of  the  TWG  comments,
they refer to BAT conclusions that are not considered to be controversial and therefore do not
seem to require further discussion, or because they are not considered to have a specific bearing
on the text of the BAT conclusions (e.g. some  methodological and implementation issues that
have already been discussed within the TXT TWG). Please note that the order of the discussion
items in this background paper will not necessarily be the order of the discussion at the meeting.

TWG  members  are  requested  to  contact  the  EIPPCB  at  least  10  working  days  before  the
TWG final meeting (i.e. by 11 of May 2021) if they wish to request the discussion of any
other  items  from  Chapter  5  (i.e.  BAT  conclusions)  at  the  meeting  or  to  propose
additional  agenda  items  for  the  meeting.  Please  note  that  the  possibility  of  including
additional items in the meeting agenda is extremely limited due to time restrictions.

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Background paper – Final meeting for the review of the TXT BREF
Each item is presented in this background paper according to the following structure (see also
below):
    the location in the first draft (D1) of the TXT BREF (December 2019) where the issue is
presented;
  the text in the first draft (D1) of the TXT BREF (December 2019) that the issue relates to;
  a summary of the comments on the issue, made by TWG members;
  the EIPPCB assessment of the comments;
  the EIPPCB proposal to resolve the issues.

Section  and  page  number  (.pdf  version)  in  the  first  draft  (D1)  of  the  TXT  BREF
(December 2019); BAT conclusion number, if applicable.
Location

in D1
Note that the numbering of the BAT conclusions may differ from  that in the first draft
(D1) of the revised TXT BREF (December 2019).
Current text
Text of the sections from the first draft (D1) of the TXT BREF (December 2019) using
in D1
the same colours (e.g. all BAT conclusions are in green).
Individual comments or a summary of the main comments related to the item.

This is done in the  following format: reference to individual comments is  made in the
format “Origin of the comment followed by the comment number”, e.g. EEB 168.

Summary of  The comments are ordered according to the text passage they refer to (e.g. comments on
comments
the introductory sentence of a BAT conclusion come first, then comments on individual
techniques in order of appearance and finally comments on performance levels).

The numbering of the comments corresponds to the numbering in the Excel spreadsheet
that compiles all comments from all TWG members.
EIPPCB
EIPPCB assessment related to the item to be discussed.
assessment
EIPPCB proposal that will be included in the latest version of the draft BAT conclusions
for discussion at the final TWG meeting.

Note  that  the  revised  BAT  conclusions  also  include  editorial  corrections  aimed  at
EIPPCB
ensuring:
proposal
1) correct and consistent language use throughout the document;
2) consistency with the most recent BAT conclusions.
Such purely editorial corrections  may not be tracked in this background paper where it
is evident that there are no substantive consequences.

The  acronym  ‘D1’  is  used  only  for  the  purposes  of  this  BP  and  will  not  appear  in  the  final
BREF or the BAT conclusions.

Working plan

After  this  final  TWG  meeting,  the  revised  draft  of  the  TXT  BREF  will  be  completed  by  the
EIPPCB  including  the  addition  of  Chapter  7  (Concluding  remarks  and  recommendations  for
future  work).  Afterwards,  the  TWG  will  be  given  another  commenting  period  of  about  four
weeks that should focus on the changes made as a result of the conclusions of the final meeting.
The  EIPPCB  will  then  take  these  comments  into  account  to  produce  the  final  draft  (FD)  that
will  be  submitted  for  opinion  to  the  IED  Article  13  Forum.  In  the  final  step,  the  BAT
conclusions  will  be  submitted  for  formal  approval  to  the  Article  75  Committee.  This  will  be
followed by the adoption of the BAT conclusions by  the Commission and their publication  in
the Official Journal of the European Union.
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Abbreviations frequently used in this background paper

Abbreviation  Meaning
AT
Austria
BAT
Best Available Techniques (as defined in Article 3(10) of the IED)
BAT-AEL
Emission levels associated with the BAT (as defined in Article 3(13) of the IED)
Environmental  performance  level  associated  with  the  BAT:  BAT-AELs  are  a  subset  of
BAT-AEPLs  (see  also  Commission  Implementing  Decision  2012/119/EU  laying  down
BAT-AEPL
rules concerning guidance on the collection of data and on the drawing up of BREFs and
on their quality assurance)
BATc
BAT conclusions
BATIS
BAT Information System
BE
Belgium
BOD
Biochemical oxygen demand
BP
Background paper
BREF
BAT reference document (as defined in Article 3(11) of the IED)
CEFIC
Conseil Européen de l’Industrie Chimique (European Chemical Industry Council)
COD
Chemical oxygen demand
BAT
reference
document
for
Common
Waste
Water
and
Waste
Gas
CWW BREF
Treatment/Management Systems in the Chemical Sector
CZ
Czech Republic
D1
First draft of the TXT BREF from December 2019
DAA
Directly associated activity
DE
Germany
DK
Denmark
ECM
Reference Document on Economics and Cross-Media Effects
EEB
European Environmental Bureau
EIPPCB
European IPPC Bureau
EKPIs
Environmental Key Performance Indicators
ELV
Emission Limit Value
EMS
Environmental Management System
European Standard adopted by CEN (European Committee for  Standardisation, from its
EN
French name Comité Européen de Normalisation)
EP(s)
Emission point(s)
ES
Spain
EURATEX
The European apparel and textile confederation
FDM BREF
BAT Reference Document on Food Drink and Milk
FI
Finland
FR
France
GOTS
Global Organic Textile Standard
HOI
Hydrocarbon oil index
IE
Ireland
IED
Industrial Emissions Directive (2010/75/EU)
International  Organisation  for  Standardisation.  Also  international  standard  adopted  by
ISO
this organisation.
IT
Italy
KEI
Key environmental issue
KoM
Kick-off Meeting
LCP BREF
BAT Reference Document on Large Combustion Plants
LVOC BREF
BAT Reference Document on Large Volume Organic Chemicals
MS
Member State(s)
NL
The Netherlands
OTNOC
Other than normal operating conditions
PL
Poland
PT
Portugal
Regulation  EC/1907/2006  on  the  Registration,  Evaluation  and  Authorisation  of
REACH
Chemicals
JRC  Reference  Report  on  Monitoring  of  emissions  to  air  and  water  from  IED
ROM
installations
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RSL
Restricted Substances List
SE
Sweden
SF BREF
Smitheries and foundries BREF
SK
Slovakia
STS BREF
BAT reference document on Surface treatment using Organic Solvents
TOC
Total organic carbon
TVOC
Total volatile organic carbon
TXT BREF
BAT reference document on Textile Industry
TWG
Technical Working Group
UK
United Kingdom
UWWTD
Urban Waste Water Treatment Directive (91/271/ECC)
VOC
Volatile organic compound
WGC BREF

WT BREF
BAT reference document on Waste Treatment
WW
Waste water
(C)WWTP
(Common) Waste water treatment plant
ZDHC
Zero Discharge of Hazardous Chemicals
ZLD
Zero Liquid DIscharge

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Background paper – Final meeting for the review of the TXT BREF
1
ITEMS PROPOSED FOR DISCUSSION AT THE FINAL TXT
TWG MEETING

1.1
Scope

Location in
P. 713 – Chapter 5
D1:
These BAT conclusions concern the following activities specified in Annex I to Directive
2010/75/EU, namely:

  6.2. Pre-treatment (operations such as washing, bleaching, mercerisation) or dyeing of
textile fibres or textiles where the treatment capacity exceeds 10 tonnes per day.
  6.11.  Independently  operated  treatment  of  waste  water  not  covered  by  Directive
91/271/EEC  provided  that  the  main  pollutant  load  originates  from  activities  covered
by these BAT conclusions.

These BAT conclusions also cover:

  The following activities when they are directly associated with activities specified in
point 6.2 of Annex I to Directive 2010/75/EU:
o  coating;
o  dry cleaning;
o  fabric production;
o  finishing;
o  lamination;
o  printing;
o  singeing;
o  wool carbonising;
o  wool fulling;
o  yarn production.
  The combined treatment of waste water from different origins provided that the main
Current
pollutant  load  originates  from  activities  covered  by  these  BAT  conclusions  and  that
text in D1:
the waste water treatment is not covered by Directive 91/271/EEC.
  On-site combustion plants which are directly associated with the activities covered by
these BAT conclusions provided that the combustion gases are put into direct contact
with the textile fibres or textiles (such as direct heating, drying, heat-setting) or when
radiant  and/or  conductive  heat  is  transferred  through  a  solid  wall  (indirect  heating)
without using an intermediary heat transfer fluid.

These BAT conclusions do not cover:

  Coating and lamination where the organic solvent consumption capacity of more than
150  kg  per  hour  or  more  than  200  tonnes  per  year.  This  is  covered  by  the  BAT
conclusions  on  surface  treatment  using  organic  solvents  including  preservation  of
wood and wood products with chemicals (STS).
  Production of man-made fibres and yarns.
  Unhairing of hides and skins. This may be covered by the BAT conclusions for the
tanning of hides and skins (TAN).

Other  BAT  conclusions  and  reference  documents  which  could  be  relevant  for  the
activities covered by these BAT conclusions include the following:

  Surface  Treatment  Using  Organic  Solvents  including  Preservation  of  Wood  and
Wood Products with Chemicals (STS);
  Tanning of Hides and Skins (TAN);
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Background paper – Final meeting for the review of the TXT BREF
  Waste Incineration (WI);
  Waste Treatment (WT);
  Emissions from Storage (EFS);
  Energy Efficiency (ENE);
  Industrial Cooling Systems (ICS);
  Monitoring of Emissions to Air and Water from IED Installations (ROM);
  Economics and Cross-Media Effects (ECM).

These BAT conclusions apply  without prejudice to other relevant legislation, e.g. on the
registration,  evaluation,  authorisation  and  restriction  of  chemicals  (REACH),  on  the
classification, labelling and packaging (CLP) or on biocidal products (BPR).
Directly associated activities
  To avoid ambiguities in implementation, add the condition that activities are carried
out  within  the  same  installation,  in  addition  to  being  directly  associated    with
activities  specified  in  point  6.2  of  Annex  I  to  Directive  2010/75/EU,  in  order  to  be
covered by the BAT conclusions (IT 1).
  Replace  "yarn  production"  with  "spinning  of  fibres"  as  production  of  man-made
fibres and yarns are not covered by these BAT conclusions (FR_A 1).
  Add  the  following  activities  to  be  covered  in  BAT  conclusions:  pre-treatments  of
cotton and cellulose fibres such as desizing and scouring, wool fulling, pre-treatments
of silk such as scouring and weighting, as some of these terms are mentioned in the
BAT conclusions and in BAT-AEPLs (IT 2).

Combined treatment of waste water
  Remove the condition on the origin of the pollutant load at the end of the bullet point
related to the 6.11 activity and delete the bullet point about the combined treatment of
waste  water.  This  is  because  these  two  points  seem  redundant  and  for  consistency
with the CWW and WT BAT conclusions (ES 41).
  Quantify  the  word  “main”  in  the  sentence  “provided  that  the  main  pollutant  load
originates from activities covered by these BAT conclusions” (EEB 169).

On-site combustion plants
  Replace the bullet point with “On-site energy generation activities which are directly
associated  with  the  activities  covered  by  these  BAT  conclusions”  as  otherwise  it
Summary
could  be  understood  that  only  combustion  techniques  are  used  to  generate  energy
of
(EEB 170).
comments:
  Delete the second part of the sentence as all combustion plants should be covered by
the BAT conclusions (EEB 170).

Interface  with  BAT  conclusions  on  surface  treatment  using  organic  solvents
including preservation of wood and wood products with chemicals (STS)
  Delete  the  exclusion  from  the  scope  of  the  BAT  conclusions  of  coating  and
lamination where the organic solvent consumption capacity  is more than 150 kg per
hour or more than 200 tonnes per year as all textiles-related BAT should be covered
in  the  TXT  BAT  conclusions.  The  STS  BAT  conclusions  would  apply  in  addition
(EEB 168).
  Add that the BAT conclusions also cover dressing, coating, degreasing and cleaning
where the organic solvent consumption capacity is less than 150 kg per hour or less
than  200  tonnes  per  year,  as  these  activities  are  not  covered  by  the  STS  BREF
(AT 31).

Reference to other BAT conclusions
  Delete  the  list  of  relevant  BAT  conclusions  and  reference  documents  as  it  is  not
useful and is confusing as to why these documents are mentioned (FR_A 3).
  Delete the reference to the BAT conclusions on Tanning of Hides and Skins (TAN) as
they do not include conclusions which might be relevant for the activities covered by
the TXT BREF (DE 94).

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Background paper – Final meeting for the review of the TXT BREF
Directly associated activities
  The  scope  of  the  BAT  conclusions  does  not  aim  to  define  the  directly  associated
activities (DAAs) but to list the activities which are covered by the BAT conclusions
when  they  are  DAAs.  The  definition  of  the  boundaries  of  an  installation  and  the
identification  of  DAAs  within  these  boundaries  remain  in  the  remit  of
implementation1. Moreover, Article 3(3)  of the IED specifies that installation  means
“a stationary technical unit within which one or more activities listed in Annex I or in
Part 1 of Annex VII are carried out, and any other directly associated activities on the
same  site  (…)”.  Therefore,  further  clarification  about  the  location  of  the  activities
which  are  covered  by  the  BAT  conclusions  when  they  are  DAAs  does  not  seem
necessary.
  As concluded at the Kick-off Meeting2 by the Technical Working Group (TWG), the
data  and  information  collection  informed  the  list  of  potential  directly  associated
activities.  Such  data  were  collected  about  spinning  but  not  about  yarn  production,
which could be clarified in a definition.
  Concerning  desizing  and  scouring,  as  pointed  out  by  the  comment,  these  are
processes  that  are  part  of  the  pretreatment  of  textile  fibres  or  textiles,  which  is
covered  by  point  6.2  of  Annex  I  to  Directive  2010/75/EU.  A  reference  to  these
processes  as  activities  covered  by  the  BAT  conclusions  when  they  are  DAAs  may
therefore be confusing. However, a clarification in the definitions of these processes
could be helpful.
  As concluded in the Kick-off Meeting by the Technical Working Group (TWG), the
data  and  information  collection  informed  the  list  of  potential  directly  associated
activities. No data were collected about pretreatment of silk.
  Wool fulling is already listed as an activity covered by the BAT conclusions when it
is a DAA.
  It  seems  necessary  to  clarify  in  the  Scope  of  these  BAT  conclusions  the  status  of
EIPPCB
activities  of  “washing  and  rinsing”  related  to  other  activities  from  definition  of
assessment:
activity 6.2 from the IED  apart from pre-treatment (e.g. dyeing and finishing).

Combined treatment of waste water
  The points related to the 6.11 activity and to the combined treatment of waste water
are both in line with the conclusions taken by the TWG at the Kick-off Meeting (see
Section 2.1.2 of the meeting report).
  Neither point is redundant:
o  In the first case, it concerns the combined treatment of waste water carried out at
an independently operated WWTP.
o  In the second case, it concerns the combined treatment of waste water carried out
at  an  installation  covered  by  point  6.2  of  the  IED  (for  example  a  textile  facility
which also treats waste water from another origin).
  The wording related to the combined treatment of waste water has evolved across the
published  BAT  conclusions  and  the  proposed  wording  is  similar  to  the  most  recent
BAT conclusions (FDM and STS).
  Data  were  collected  during  the  data  collection  about  the  share  of  waste  water
originating  from  textile  activities.  This  share  is  however  expressed  in  percentage  in
volume and not in terms of pollutant load, which makes it difficult to further specify
the  meaning  of  “main  pollutant  load”.  As  an  indication,  the  lowest  share  of  waste
water originating from textile activities is  14 % as an average over 3 years for  Plant
CZ020.

On-site combustion plants
  The  paragraph  on  combustion  plants  aims  to  specify  in  which  cases  combustion
plants  are  covered  by  the  BAT  conclusions.  It  does  not    imply  that  non-combustion
energy generation cannot be used.
  Deleting  the second part  of  the  sentence  would  not be  in  line  with the  conclusions
taken by the TWG at the Kick-off Meeting (see Section 2.2.2 of the meeting report).

1  See  “ANSWERS  GIVEN  BY  DG  ENVIRONMENT  ON  THE  IMPLEMENTATION  OF  THE  INDUSTRIAL  EMISSIONS
DIRECTIVE
–
CHAPTER
1”at
https://circabc.europa.eu/sd/a/cd4fc56b-cb31-4a39-bed7-
166a4e33e2d2/Chapter%201%20Q%26A.pdf
2  Kick-off  Meeting  report  referenced  Ares(2018)4698733  at  https://eippcb.jrc.ec.europa.eu/sites/default/files/2019-
11/TXT_KoM_meeting_report_Sept18.pdf
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Background paper – Final meeting for the review of the TXT BREF
Interface  with  BAT  conclusions  on  surface  treatment  using  organic  solvents
including preservation of wood and wood products with chemicals (STS)
  Deleting  the  exclusion  from  the  scope  of  the  BAT  conclusions  of  coating  and
lamination where the organic solvent consumption capacity  is more than 150 kg per
hour or more than 200 tonnes per year would not be in line with the conclusions taken
by the TWG at the Kick-off Meeting as it would create an overlap with the STS BAT
conclusions (see Section 2.2.3 of the meeting report).
  As  mentioned  in  the  Scope,  coating  is  covered  by  the  BAT  conclusions  when  it  is
DAA  and  where  the  organic  solvent  consumption  capacity  is  less  than  150  kg  per
hour or less than 200 tonnes per year.
  Concerning  degreasing  and  cleaning,  it  is  not  clear  how  these  processes  relate  to
textiles  activities.  Solvent-based  degreasing  and  cleaning  may  be  used  for  machines
but  this  is  the  case  in  many  industrial  sectors.  It  is  therefore  not  clear  why  these
processes should be covered by the TXT BAT conclusions when they are not covered
by the STS BAT conclusions.
  Concerning dressing, it may refer to textiles activities but the meaning of this term is
ambiguous.  Depending  on  the  sources,  it  refers  to  finishing,  dyeing3  or  sizing4.
Moreover, no information was collected about dressing during the data collection.

Reference to other BAT conclusions
  It is common practice  in all  recent BAT  conclusions to list other BAT conclusions
and  reference  documents  which  could  be  relevant  for  the  activities  covered  by  the
BAT  conclusions  concerned.  For  example,  the  ENE BREF  may  contain  useful
information to improve the energy efficiency of the installation.
  Concerning the reference to the TAN BAT conclusions, they do not seem relevant for
the  activities  covered  by  the  TXT  BAT  conclusions  as  the  latter  do  not  cover
unhairing of hides and skins.
  Some  activities  of  the  STS BAT conclusions  could  be  relevant  for  the  TXT   sector
(e.g. impregnation, coating).

Other points
  Although not addressed by any comment, the exclusion from the scope of production
of man-made yarns could be confusing as yarns are always man-made and this would
exclude for example the spinning of wool fibres. This expression refers in fact to the
spinning of man-made fibres, which could be further clarified.
  To define yarn production as spinning.
  To  specify that  only the  production of  yarns  made  of  man-made  fibres is excluded
from  the  scope  of  the  BAT  conclusions.  To  reflect  this  change  to  the  title  of  the
EIPPCB
section 5.3.
proposal:
  To clarify that “washing and rinsing” is directly associated activity.
  To clarify in the Definitions that desizing and scouring are part of the pretreatment
processes.
  To remove the reference to the TAN BAT conclusions.


3 https://patents.google.com/patent/DE2715862A1/en
4 https://www.britannica.com/topic/textile/Finishes-enhancing-tactile-qualities
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1.2
Definitions

Location in
P. 715 – Chapter 5
D1:
For the purposes of these BAT conclusions, the following definitions apply:
General terms
Term used
Definition
Cellulosic materials
Cellulosic materials include cotton and viscose.
Channelled
Emissions of pollutants to air through any kind of duct, pipe,
emissions
stack, etc.
Continuous
Measurement
using
an
automated
measuring
system
measurement
permanently installed on site.
Desizing
Removal of sizing chemicals.
Diffuse emissions
Non-channelled emissions to air.
Discharge  to  a  receiving  water  body  without  further
Direct discharge
downstream waste water treatment.
Dry cleaning
Cleaning of textile materials with an organic solvent.
Existing plant
A plant that is not a new plant.
Physical and/or chemical treatment aiming at giving the textile
Finishing
materials  end-use  properties  such  as  visual  effect,  handle
characteristics, waterproofing or non-flammability.
Hazardous waste as defined in point 2 of Article 3 of Directive
Hazardous waste
2008/98/EC.
Indirect discharge
Discharge which is not a direct discharge.
For a batch process, weight ratio between the dry textile
Liquor ratio
materials and the process liquor used.
A  major  change  in  the  design  or  technology  of  a  plant  with
Major plant upgrade
major  adjustments  or  replacements  of  the  process  and/or
abatement technique(s) and associated equipment.
The  mass  of  a  given  substance  or  parameter  which  is  emitted
Mass flow
Current
over a defined period of time.
text in D1:
A  plant  first  permitted  at  the  site  of  the  installation  following
the  publication  of  these  BAT  conclusions  or  a  complete
New plant
replacement of a plant  following the publication of these BAT
conclusions.
Organic  solvent  as  defined  in  Article  3(46)  of  Directive
Organic solvent
2010/75/EU.
Periodic
Measurement  at  specified  time  intervals  using  manual  or
measurement
automated methods.
For a continuous process, weight ratio between the liquid taken
Pick-up
up by the textile materials and the dry textile materials.
Substances  and/or  mixtures  as  defined  in  Article  3  of
Regulation  EC/1907/2006  and  used  in  the  process(es),
Process chemicals
including sizing chemicals, bleaching chemicals, dyes, printing
pastes and finishing chemicals.
Process liquor
Solution and/or suspension containing process chemicals.
Impregnation of yarn  with process chemicals aiming to protect
Sizing
the yarn and provide lubrication during weaving.
Synthetic materials
Synthetic materials include polyester, polyamide and acrylic.
Textile materials
Textile fibres and/or textiles.
Thermal  treatment  of  textile  materials  includes  drying,  curing,
Thermal treatment
fixing  or  heat-setting  which  is  carried  out  as  a  process  step  of
the activities covered by these BAT conclusions.

Pollutants and parameters
Term used
Definition
Antimony,  expressed  as  Sb,  includes  all  inorganic  and  organic
Antimony
antimony compounds, dissolved or bound to particles.
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Background paper – Final meeting for the review of the TXT BREF
Adsorbable  organically  bound  halogens,  expressed  as  Cl,
AOX
include  adsorbable  organically  bound  chlorine,  bromine  and
iodine.
Biochemical oxygen demand. Amount of oxygen needed for the
biochemical  oxidation  of  the  organic  matter  to  carbon  dioxide
BODn
in  n  days  (n  is  typically  5  or 7).  BODn  is  an  indicator  for  the
mass concentration of biodegradable organic compounds.
Chromium, expressed as Cr, includes all inorganic and organic
Chromium
chromium compounds, dissolved or bound to particles.
CO
Carbon monoxide.
Chemical  oxygen  demand.  Amount  of  oxygen  needed  for  the
total chemical oxidation of the organic matter to carbon dioxide
COD
using  dichromate.  COD  is  an  indicator  for  the  mass
concentration of organic compounds.
Copper,  expressed  as  Cu,  includes  all  inorganic  and  organic
Copper
copper compounds, dissolved or bound to particles.
Dust
Total particulate matter (in air).
Hydrocarbon oil index. The sum of compounds extractable with
a  hydrocarbon  solvent  (including  long-chain  or  branched
HOI
aliphatic,  alicyclic,  aromatic  or  alkyl-substituted  aromatic
hydrocarbons).
NH3
Ammonia.
Nickel,  expressed  as  Ni,  includes  all  inorganic  and  organic
Nickel
nickel compounds, dissolved or bound to particles.
The  sum  of  nitrogen  monoxide  (NO)  and  nitrogen  dioxide
NOX
(NO2), expressed as NO2.
The  sum  of  sulphur  dioxide  (SO
SO
2),  sulphur  trioxide  (SO3),  and
X
sulphuric acid aerosols, expressed as SO2.
The  sum  of  dissolved  sulphides  and  of  those  undissolved
Sulphide,
easily  sulphides that are easily released upon acidification, expressed
released
as S2–.
Total  organic  carbon,  expressed  as  C  (in  water),  includes  all
TOC
organic compounds.
Total  nitrogen,  expressed  as  N,  includes  free  ammonia  and
TN
ammonium nitrogen (NH –
–
4 N), nitrite nitrogen (NO2 N), nitrate
nitrogen (NO –
3 N) and organically bound nitrogen.
Total  phosphorus,  expressed  as  P,  includes  all  inorganic  and
TP
organic  phosphorus  compounds,  dissolved  or  bound  to
particles.
Total  suspended  solids.  Mass  concentration  of  all  suspended
TSS
solids  (in  water),  measured  via  filtration  through  glass  fibre
filters and gravimetry.
TVOC
Total volatile organic carbon, expressed as C (in air).
Volatile  organic  compound  as  defined  in  Article  3(45)  of
VOC
Directive 2010/75/EU.
Zinc,  expressed  as  Zn,  includes  all  inorganic  and  organic  zinc
Zinc
compounds, dissolved or bound to particles.

Additional terms
  Add the  definitions  of coating, singeing,  flame  lamination and fabric  production  as
these terms are mentioned in the BAT conclusions and in BAT-AEPLs (UK 2).

Hazardous waste
  For clarification and coherence, use the hazard classes and definition of the regulation
Summary
on  classification,  labelling  and  packaging  of  substances  and  mixtures  (CLP)
of
(CEFIC 4).
comments:

Thermal treatment
  Change  the  definition  as  follows:  “All  thermal  treatments  where  relevant  air
emissions  can  occur  like  drying  after  finishing  or  printing  or  lamination  or  coating,
fixing  or  heat-setting  of  textiles,  certain  dyeing  processes  like  thermosol  or  dyeing
with carriers” because the definition should also cover the thermosol dyeing process
and dyeing with carriers (DE 58, DE 410).
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Chromium, copper, nickel, zinc
  Modify  the  chromium  definition  as  follows:  “Chromium,  expressed  as  total  Cr,
includes  all  inorganic  and  organic  chromium  compounds,  dissolved  or  bound  to
particles” because the monitoring standard measures all types of chromium. The same
applies  for  copper,  nickel  and  zinc  (EURATEX 23,  EURATEX 24,  EURATEX 25,
EURATEX 26, ES 28, ES 29, ES 30, ES 31).
Additional terms
  Coating and lamination are activities mentioned in Annex I and Annex VII to the IED
and  it  is  not  the  aim  of  the  BAT  conclusions  to  give  an  interpretation  of  the  IED.
These terms are not defined in the STS BAT conclusions either.
  The definitions of flame lamination, singeing and fabric production could add clarity
as they are used in the BAT conclusions.

Hazardous waste
  As mentioned in Article 1(3) of the CLP Directive, this Directive does not apply to
waste.  The  definition  of  hazardous  waste  is  given  in  Directive  2008/98/EC  and  the
same  definition  has  been  used  in  a  number  of  recently  published  BAT  conclusions
(WT, WI).

Thermal treatment
  According  to  Section 2.7.8  of  D1,  emissions  to  air  from  dyeing  are  generally  not
significant  except  from  the  thermosol  process  and  from  dyeing  processes  using
carriers.
  The thermosol process is specific for dyeing polyester or cotton/polyester blends with
EIPPCB
disperse  dyestuffs.  The  sequence  of  this  process  is  as  follows:  impregnation  in  the
assessment:
dyeing  liquor,  pre-drying  in  an  infrared  oven,  drying  in  hot-flue,  thermal  fixation  at
200 ºC. All steps of pre-drying, drying and thermal fixation are encompassed by the
definition  proposed  in  D1  and  specific  mention  of  the  thermosol  process  does  not
seem necessary.
  Concerning dyeing processes using carriers,  according to Section 2.7.8.1 of D1, the
carriers  that  remain  on  the  fibre  after  dyeing  and  washing  are  partially  volatilised
during drying and fixing operations and can give rise to emissions to air. Both drying
and fixing are covered by the definition proposed in D1 and mention of dyeing using
carriers does not seem necessary.

Chromium, copper, nickel, zinc
  The monitoring standards mentioned in the BAT conclusions allow the measurement
of  all  forms  of  these  metals.  This  is  underlined  in  the  definitions  proposed  in  D1:
“(…)  includes  all  inorganic  and  organic  (…)  compounds,  dissolved  or  bound  to
particles”.  While  adding  “expressed  as  total  Cr”  (or  Cu,  Ni  and  Zn)  could  be  an
option,  it  would  be  a  repetition  of  the  definition  and  would  not  be  in  line  with  the
recently published BAT conclusions (e.g. WI and WT).

  To add the definitions of flame lamination, singeing and fabric production.
  To add or modify the definitions of desizing, scouring and hazardous substances (see
assessments of BAT 4 in Section 1.4.1.1 or BAT 13 in Section 1.4.5.1).
EIPPCB
  The  definition  of  “substances  of  very  high  concern”  was  added  and  the  one  of
proposal:
“process chemicals” modified (assessment in 1.4.5.1).
  The  definition  of  “thermal  treatment”  was  modified  to  accommodate  the  needs  of
many BATs (e.g. see assessments in section 1.4.8).
  To add a definition of CMR (see assessment in 1.4.2.1).

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1.3
General considerations

1.3.1
Emission levels associated with the best available techniques
(BAT-AELs) for emissions to air

Location in
P. 717 – Chapter 5
D1:
When a mass flow threshold is indicated, the BAT-AELs only apply if the mass
flow of the given substance or parameter emitted from the emission point is above
the associated mass flow threshold.

Emission  levels  associated  with  the  best  available  techniques  (BAT-AELs)  for
emissions to air given in these BAT conclusions refer to concentrations (mass of
emitted  substances  per  volume  of  waste  gas)  under  the  following  standard
conditions:  dry  gas  at  a  temperature  of  273.15 K  and  a  pressure  of  101.3 kPa,
without correction for oxygen content, and expressed in mg/Nm3.

Current
For averaging periods of BAT-AELs for emissions to air, the following definition
text in D1:
applies.

Type of
Averaging period  Definition
measurement
Average
value
of
three
consecutive
Average over the
Periodic
measurements  of  at  least  30  minutes  each.
sampling period
(1)
(1)  For  any  parameter  where,  due  to  sampling  or  analytical  limitations,  a  30-minute
sampling/measurement  and/or  an  average  of  three  consecutive  measurements  is
inappropriate, a more representative sampling/measurement procedure may be employed.

General points
  Add a provision to avoid the dilution of emissions to air when waste gas streams are
combined,  such  as  “if  the  waste  gases  from  several  parts  of  the  installation  are
combined,  the  requirements  to  reduce  emissions  shall  be  established  in  a  way  to
ensure that the emissions generated do not exceed an emission level of the respective
gases where they are disposed of individually” (DE 124).
  Mention  that  the  measurements  are  carried  out  at  the  highest  expected  emission
concentrations under normal operating conditions (DE 126).

Mass flow thresholds
  Apply  the  mass  flow  thresholds  at  installation  level  to  which  the  sum  of  the  mass
flows of the different emission sources would be compared; otherwise, each emission
point  could  be  below  the  mass  flow  threshold  if  the  number  of  emission  points  is
increased (SE 20, DE 60, DE 75, DE 122).
Summary
  On the basis of measurements, flows that do not (significantly) contribute to the total
of
mass flow at plant level may be left out of consideration (SE 20).
comments:

Emissions to air from thermal treatment
  The BAT-AELs related to emissions from all thermal treatments should refer to an air
/ textile weight ratio of 20 m3/kg textile to be treated. Indeed, by using a lot of air, the
waste gas emission concentration will be lower. However, a large excess of drying air
is not energy-efficient (DE 85, DE 381).

Averaging periods
  Change the definition to “average value of three consecutive individual measurements
of a sampling period of at least 30 minutes each” (DE 61).

Batch processes
  Add  provisions  to  ensure  a  homogeneous  implementation,  i.e.  homogeneous
calculation of the mass flows (e.g. sampling period, number of batches), in particular
when processes are carried out in batches (UK 3).
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  Add  a  footnote  for  the  batch  processes:  “For  batch  processes,  the  average  of  a
representative number of measurements taken over the total batch time or the result of
a  measurement  carried  out  over  the  total  batch  time,  during  which  emissions  occur,
but with a maximum of 4 hours, can be used." (BE 36).

General points
  How to establish emission limit values for combined waste gas streams, considering
the pollutant loads of the individual waste gas streams, seems to pertain to the domain
of  implementation.  In  addition,  such  provisions  would  not  be  in  line  with  other
recently published BAT conclusions.
  Footnote (1) of BAT 8 mentions that the measurements are carried out at the highest
expected  emission  state  under  normal  operating  conditions  and  it  does  not  seem
needed to repeat the text in the General considerations.
Mass flow thresholds
  Regarding the mass flow threshold preventing increased number of emissions points
BAT 22 instructs to limit them. Furthermore, article 20 of the IED sets that operators
should report MS about any change in the installation that may have consequences for
the  environment,  meaning  that  such  change  would  require  change  of  permit  and
decision  of  competent  authority  (which  would  need  to  base  their  decision  on  BAT
22).
  Following  the  interventions  of  the  different  TWG  members  during  the  informal
meeting of 19/02/2021,  it seemed that  there  was not a common position on  whether
some emission points with small mass flows are considered relevant and would need
to  comply  with  BAT-AEL,  and  others  irrelevant  (or  insignificant  in  terms  of
environmental impact) and would not need to comply with BAT-AEL. Approaches to
set such mass flow threshold are described in sections 1.4.8.3, 1.4.8.5 and 1.4.8.7.
  However,  taking  into  account  plant  configurations  where  the  emissions  to  air  from
one  source  could  be  discharged  through  more  than  one  emission  point.  It  could  be
clarified in General considerations how to calculate the mass flow taking into account
all  the  emission  points  related  to  a  common  source  could  be  considered  as  a  single
EIPPCB
emission point.

assessment:  Emissions to air from thermal treatment
  Increasing the volume of extracted air leads indeed to the dilution of the pollution in
the waste gas stream. This is the case across all industrial sectors and is not specific to
the textile industry. How the dilution is considered for setting ELVs seems to be more
an implementation issue and follows the provisions set in Article 15(1) of the IED.
  Concerning  energy  efficiency,  this  is  addressed  by  BAT  10,  11  and  12  and  by  the
BAT-AEPL set in Table 5.2.

Averaging periods
  The wording “average value of three consecutive measurements of at least 30 minutes
each”  is  a  standard  wording  which  has  been  used  in  all  recently  published  BAT
conclusions and any change needs to be considered carefully.
  When the measurements are carried out on-line, the duration of 30 minutes refers also
to the sampling as the sampling and the measurements are simultaneous. This is not
the case though of off-line measurements where the sampling may last 30 minutes but
the  measurement  itself  is  shorter  (for  example  in  the  case  of  dust  monitoring  as  per
standard EN 13284-1). This could be reflected in the BAT conclusions.

Batch processes
  Concerning the homogeneity of the measurement practices when the textile materials
are  processed  in  batches,  this  is  covered  by  Footnote  (1)  of  BAT  8  mentioning  that
the measurements are carried out at the highest expected emission state under normal
operating conditions.
  Footnote  (1)  applies  also  to  the  cases  of  batch  processes.  It  provides  appropriate
guidance  on  how  to  perform  the  sampling/measurements  in  implementation  to  the
batch processes.

Averaging periods
  To specify the sampling duration in the case of off-line measurements.
EIPPCB
  To clarify that  several emission points associated with the same source  of emission
proposal:
can be considered as single emission point when to calculating the mass flows
  To delete the applicability of the BAT-AELs when there is a mass flow threshold
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1.3.2
Emission levels associated with the best available techniques
(BAT-AELs) for emissions to water

Location in
P. 717 – Chapter 5
D1:
Emission levels associated with the best available techniques (BAT-AELs) for emissions
to  water  given  in  these  BAT  conclusions  refer  to  concentrations  (mass  of  emitted
substances per volume of water), expressed in mg/l.

Averaging  periods  associated  with  the  BAT-AELs  refer  to  either  of  the  following  two
cases:

Current
  in  the  case  of  continuous  discharge,  daily  average  values,  i.e.  24-hour  flow-
text in D1:
proportional composite samples;
  in the case of batch discharge, average values over the release duration taken as flow-
proportional composite samples, or, provided that the effluent is appropriately mixed
and homogeneous, a spot sample taken before discharge.

Time-proportional composite samples can be used provided that sufficient flow stability is
demonstrated.
Summary
  Mention  that  all  BAT-AELs  for  emissions  to  water  apply  at  the  point  where  the
of
emission leaves the plant, as in the STS BAT conclusions (AT 35).
comments:
  According  to  Article  15(1)  of  the  IED,  the  emission  limit  values  for  polluting
EIPPCB
substances  shall  apply  at  the  point  where  the  emission  leaves  the  installation.
assessment:
Although it may not be necessary to add a similar provision in the BAT  conclusions,
it would bring consistency with other recently published BAT conclusions.
  To add a sentence to specify where the BAT-AELs for emissions to water apply.
EIPPCB
  To  move  the  provision  for  time-proportional  composite  sampling  to  the  case  of
proposal:
continuous discharge.

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1.3.3
Specific energy consumption levels associated with the best
available techniques

Location in
P. 718 – Chapter 5
D1:
The  environmental  performance  levels  related  to  specific  energy  consumption  refer  to
yearly averages calculated using the following equation:

energy consumption
specific energy consumption =

activity rate

Current
where:
text in D1:

energy consumption:
the  total  annual  amount  of  heat  and  electricity
consumed  by  a  given  process,  minus  the  heat
recovered from the process, expressed in MWh/year;

activity rate:
total annual amount of textile  materials treated in the
process, expressed in t/year.
Summary
  Clarify the definition of activity rate as the textile materials could undergo the same
of
process  several  times,  involving  thermal  treatments  carried  out  as  process  steps,
comments:
and/or different processes, each of which may involve thermal treatments (IT 3).
  The specific energy consumption was reported through the questionnaires used in the
data  collection.  These  questionnaires  specified  that  the  specific  energy  consumption
was calculated as the energy consumed during a reference year divided by the weight
of textiles treated in this process during the same year. Therefore, counting only once
the amount of textile materials processed several times would not be in line with the
definition used in the questionnaires and for the derivation of BAT-AEPLs. It could
EIPPCB
be helpful however to clarify this point in the BAT conclusions.
assessment:
  Although  no  comments  were  made  on  this  issue,  the  proposed  BAT-AEPLs  in
Table 5.2  concern  only  thermal  treatment  and  not  all  the  processes,  which  could  be
reflected in the General considerations.
  In accordance with assessments in section 1.4.4.3 the indicative levels are proposed
instead of BAT-AEPLs. This can be reflected in the equation for calculating specific
energy consumption.
  To  clarify  that  the  amount  of  textile  materials  treated  in  the  process  includes  the
EIPPCB
textile materials processed several times in the same process.
proposal:
  To replace “process” with “thermal treatment”.
  To change from BAT-AEPLs to “indicative levels”.

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link to page 21 Background paper – Final meeting for the review of the TXT BREF
1.3.4
Specific water consumption levels associated with the best
available techniques

Location in
P. 718 – Chapter 5
D1:
The  environmental  performance  levels  related  to  specific  water  consumption  refer  to
yearly averages calculated using the following equation:

water consumption
specific water consumption =

activity rate

where:
Current

text in D1:
water consumption:
the total annual amount of water consumed by a given
process including  water used for  washing and rinsing
the  textile  materials  and  for  cleaning  the  equipment,
minus  the  water  reused  or  recycled  to  the  process,
expressed in m3/year;

activity rate:
total annual amount of textile  materials treated in the
process, expressed in t/year.
  Clarify  that  specific  water  consumption  at  a  process  level  concerns  only  the  water
consumed  by  the  process  concerned  and  does  not  contain  other  waste  water  flows
(UK 4).
Summary
  Clarify the definition  of water consumption as follows: “the total annual amount of
of
water  consumed  by  a  given  specific  process  (e.g.  mercerisation)  (…)”  as  Table 5.1
comments:
refers to specific processes (IT 5).
  Clarify  the  definition  of  activity  rate  as  follows:  “total  annual  amount  of  textile
materials treated in the specific processes (e.g. mercerisation), expressed in t/year” as
Table 5.1 refers to specific processes (IT 6).
  The proposed definition of water consumption corresponds to the total annual amount
of  water  consumed  by  a  given  process.  It  does  not  seem  necessary  to  add  that  it
excludes the water not consumed by this process. Moreover, BAT 5 specifies that the
monitoring is broken down to the process level.
EIPPCB
  It is not entirely clear whether the addition of the word “specific” in the definitions of
assessment:
water  consumption  and  activity  rate  would  add  clarity.  However,  examples  of
processes could be helpful.
  In accordance with assessments in section 1.4.3.2 the indicative levels are proposed
instead of BAT-AEPLs. This can be reflected in the equation for calculating specific
water consumption.
  To add examples of processes.
EIPPCB
  To  clarify  that  the  amount  of  textile  materials  treated  in  the  process  includes  the
proposal:
textile materials processed several times in the same process (see Section 1.3.3).
  To change from BAT-AEPLs to “indicative levels”.

22
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Background paper – Final meeting for the review of the TXT BREF
1.3.5
Specific wool grease recovery level associated with the best
available techniques

Location in
P. 718 – Chapter 5
D1:
The environmental performance level related to specific wool grease recovery  refers to a
yearly average calculated using the following equation:

amount of wool grease recovered
specific wool grease recovery =

activity rate

Current
where:
text in D1:

amount of wool grease recovered:
the  total  annual  amount  of  wool
grease  recovered  from  the  pre-treatment  of  raw  wool
fibres by scouring, expressed in kg/year;

activity rate:
total annual amount of raw wool pre-treated by scouring,
expressed in t/year.
Summary
of
  No comments.
comments:
EIPPCB
  Not applicable.
assessment:
EIPPCB
  No change.
proposal:

1.3.6
Caustic soda recovery level associated with the best available
techniques

Location in
P. 719 – Chapter 5
D1:
The  environmental  performance  level  related  to  caustic  soda  recovery  refers  to  a  yearly
average calculated using the following equation:

amount of caustic soda recovered
caustic soda recovery =

amount of caustic soda before recovery

where:
Current

text in D1:
amount of caustic soda recovered:
the  total  annual  amount  of  caustic
soda
recovered
from
spent
mercerisation
rinsing
water,
expressed in kg/year;

amount of caustic soda before recovery:
total  annual  amount  of  caustic  soda
in  the  spent  mercerisation  rinsing
water, expressed in kg/year.
Summary
of
  No comments.
comments:
EIPPCB
  Not applicable.
assessment:
EIPPCB
  No change.
proposal:
BZ/JR/JG/DDG/EIPPCB/TXT FM BP
March 2021
23

Background paper – Final meeting for the review of the TXT BREF
1.4
General BAT conclusions

1.4.1
Overall environmental performance

1.4.1.1
Techniques for improving the overall environmental performance

Location in
P. 721 – Section 5.1.1 – BAT 2
D1:
BAT  2.  In  order  to  improve  the  overall  environmental  performance,  BAT  is  to
establish,  maintain  and  regularly  review  (including  when  a  significant  change
occurs)  an  inventory  of  inputs  and  outputs,  as  part  of  the  environmental
management system (see BAT 1), that incorporates all of the following features:

(i) information about the production process(es), including:
(a) simplified process flow sheets that show the origin of the emissions;
(b)  descriptions  of  process-integrated  techniques  and  waste  water/waste  gas
treatment  techniques  to  prevent  or  reduce  emissions,  including  their
performance (e.g. abatement efficiency);
(ii)  information  about  the  quantity  and  characteristics  of  materials  used,  including
textile materials and process chemicals (see BAT 14);
(iii) information about water consumption;
(iv) information about energy consumption;
(v) information about the quantity and characteristics of the waste water streams, such
as:
(a) average values and variability of flow, pH, temperature, and conductivity;
Current
(b) average concentration and mass flow values of relevant substances/parameters
text in D1:
and  their  variability  (e.g.  COD/TOC,  nitrogen  species,  phosphorus,  metals,
priority substances, microplastics);
(c)  data  on  toxicity  and  bioeliminability  (e.g.  BODn,  BODn  to  COD  ratio,  Zahn-
Wellens  test,  biological  inhibition  potential  (e.g.  inhibition  of  activated
sludge));
(vi) information about the characteristics of the waste gas streams, such as:
(a) average values and variability of flow and temperature;
(b) average concentration and mass flow values of relevant substances/parameters
and their variability (e.g. dust, organic compounds);
(c) flammability, lower and higher explosive limits, reactivity;
(d) presence of other substances that may affect the waste gas treatment system or
plant safety (e.g. water vapour, dust);
(vii) information about the quantity and characteristics of waste generated.

Applicability
The scope (e.g. level of detail) and nature of the inventory will generally be related to the
nature, scale and complexity of the installation, and the range of environmental impacts it
may have.
General comments
  Add  a  yearly  based  frequency  for  reviewing  the  inventory  of  inputs  and  outputs
(DE 335).
  Define  the  term  "significant  change"  so  that  it  could  be  implemented  by  Member
States in a homogeneous way (DE 387).
  Express units per year, e.g. m3/year, kg/year (DE 335).
  Add  at  the  end  of  the  BAT  statement  that  the  inventory  incorporates  all  of  the
Summary
following features, only if they are relevant (EURATEX 142).
of
  Streamline  and  harmonise  text  (both  wording  and  consecutive  numbering)  on
comments:
inventory  of  inputs  and  outputs  with  the  respective  text  in  the  FDM  BREF  or  other
BREFs (AT 33).
  Add  a  reference  to  BAT  16,  “Techniques  for  preventing  or  reducing  emissions  to
water of poorly biodegradable substances”, as they are very closely aligned  (UK 6).
  Clarify the use of "such as" in points (v) and (vi). If operators are expected to conduct
several tests on toxicity, bioeliminability. it could be expensive and time-consuming
(UK 6).
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Background paper – Final meeting for the review of the TXT BREF
Waste water streams
  Add clarification on the differences of the measurement methods (BOD5, RODTOX
(biological  inhibition  test)  and  Zahn  Wellens  test),  to  help  choose  the  appropriate
method or combination of methods (BE 32).

Microplastics
  Add  that  testing  for  microplastics  is  done  according  "to  an  agreed  test  method  or
standard"  to  avoid  further  uncertainty  when  trying  to  compare  test  results  from
different sites in the future (UK 6).
  Delete  "microplastics"  since  there  is  still  no  valid  measurement  standard  for
microplastics  (currently  under  development  within  CEN  TC248),  so  there  is  no
possiblity to be compliant or at least for comparing results. Furthermore, relevance is
presently
not
scientifically
confirmed
(CEFIC 20,
EURATEX 28
and
EURATEX 143).
  Keep microplastics monitoring in the proposed BAT (EEB 99).

Waste gas streams
  Delete the term "average" in points (vi) a) and (vi) b), since having information on
highest emissions levels and their context (e.g. recipes, hazardous substances used) is
as useful as information on average levels to prevent and reduce emissions (DE 63).
  Add  a  bullet  point  on  the  identification  of  hazardous  pollutants  and  the  related
emissions  to  air  of  each  applied  recipe  for  textile  finishing  processes,  based    on  the
emission factor concept (DE 64 and DE 413).

General comments
  It may be necessary to review the inventory more than once per year if the process
conditions  vary  very  frequently,  for  example  in  the  case  of  companies  working  on
commission. In contrast, if the process conditions are stable, there may be not merit in
reviewing  this  inventory  every  year.  The  proposed  wording  reflects  this  variety  of
cases, offers  flexibility and is in line  with recently published BAT  conclusions such
as FDM.
  The units used for the inventory are an operational detail which can be addressed at
the implementation stage.
  Concerning the relevance of the proposed features, it is not clear in which cases one
of  those  features  would  not  be  relevant.  Of  course,  if  no  water  is  used  in  the
processes, obviously point (iii) about water consumption would indicate that no water
is consumed but this case seems very specific.
  The text in BAT 2 has been used in recent documents such as FMP, and presents the
principles  of  the  inventory  of  inputs  and  outputs  as  part  of  the  environmental
management  system.  The  text  has  been  adapted  for  the  textile  industry  and  the
applicability clarifies the interpretation of this BAT, giving flexibility at local scale. It
seems possible to harmonise wording and numbering with the recent text used for the
EIPPCB
FDM industry.
assessment:
  Otherwise, the link with the specific BAT 16 is unclear, as the scope of BAT 2 is the
overall environmental performance.

Waste water streams
  More  information  for  choosing  a  relevant  measurement  method  can  be  found  in
Chapter 4 of D1 or in the Reference Document for monitoring of emissions to air and
water from IED installations. Moreover, the choice of an appropriate method to refer
to  in  order  to  obtain  data  on  toxicity  and  bioeliminability  may  depend  on  the  local
situation or process parameters.
  Following the assessment of comment DE 340 on BAT 8 (on biodegradability) on the
usefulness of information on  the biodegradability of individual  waste  water streams,
to handle them appropriately, it seems relevant to add biodegradability to point (v)(c)
as relevant information on waste water streams.

Microplastics
  As mentioned in Section 3.4.19, microplastics have been measured in several studies
involving the textile industry, and a standardised European measurement method for
microplastics  is  currently  under  development  (see  CEN/TC  248/WG  37  -
Microplastics from textile sources).
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Background paper – Final meeting for the review of the TXT BREF
  Microplastics  is  only  one  example  of  relevant  substances/parameters  mentioned  in
point (v).

Waste gas streams
  The  text  in  BAT  2  is  used  in  many  conclusions  from  the  CWW  BAT  conclusions
onward  and  includes  average  values  and  variability  for  the  parameters  listed,  which
includes data on highest emissions levels.
  The  variability  of  the  characteristics  of  the  waste  gas  streams  may  indeed  be
estimated by the use of emission factors, which could be reflected in BAT 2.
  To make minor text adjustments on wording and numbering.
EIPPCB
  To add a reference to emission factors.
proposal:
  To add the biodegradability in point (v)(c).

BAT  2bis.  In  order  to  reduce  the  frequency  of  the  occurrence  of  OTNOC  and  to
reduce  emissions  during  OTNOC,  BAT  is  to  set  up  and  implement  a  risk-based
OTNOC  management  plan  as  part  of  the  EMS  (see  BAT  1)  that  includes  all  of  the
following elements:

i.
identification of potential OTNOC (e.g. failure of equipment critical to the
protection  of  the  environment  (‘critical  equipment’)),  of  their  root  causes
and  of  their  potential  consequences,  and  regular  review  and  update  of  the
list of identified OTNOC following the periodic assessment below;
New
ii.
appropriate design of critical equipment (e.g. waste water treatment);
proposal
iii.
set-up  and  implementation  of  an  inspection  and  preventive  maintenance
plan for critical equipment (see BAT 1 xii);
iv.
monitoring (i.e. estimating or, where possible, measuring) and recording of
emissions during OTNOC and of associated circumstances;
v.
periodic  assessment  of  the  emissions  occurring  during  OTNOC  (e.g.
frequency  of  events,  duration,  amount  of  pollutants  emitted)  and
implementation of corrective actions if necessary;
vi.
regular  review  and  update  of  the  list  of  identified  OTNOC  under  point  i.
following the periodic assessment of point v;
vii.
regular testing of back-up systems.
Summary
of
  Not applicable
comments:
  Based on the data collection there are substantial fluctuations in the reported values of
emissions  to  air  and  water  from  some  plants.  The  cause  of  these  fluctuations  is  not
EIPPCB
known, however it seems that one of the possible reasons could be a poor operational
assessment:
management  of  the  abatement  techniques,  resulting  in  other  than  normal  operating
conditions. These could be prevented by appropriate management practice.
EIPPCB
  To add BAT 2bis.
proposal:

26
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link to page 83 Background paper – Final meeting for the review of the TXT BREF
1.4.2
Monitoring

1.4.2.1
Monitoring emissions to water

Location
P. 724 – Section 5.1.2– BAT 7
in D1:
BAT 7. BAT is to monitor emissions to water with at least the frequency given below
and in accordance with EN standards. If EN standards are not available, BAT is to use
ISO, national or other international standards that ensure the provision of data of an
equivalent scientific quality.

Activities
Minimum
Monitoring
Substance(s) /
Standard(s)
/
monitoring
associate
parameter
processes
frequency
d with
Adsorbable
Once
every
organically
bound  EN ISO 9562
month
halogens (AOX) (1)
EN
standards
available  for  some
alkylphenols
and  All
Alkylphenols
and  alkylphenol
activities  /  Once
every
alkylphenol
ethoxylates
processes
3 months
ethoxylates (1)
(i.e. EN ISO 18857
-1
and
EN ISO 18857-2)
Biochemical
oxygen
Once
every
EN 1899-1
demand (BODn) (2)
month
To be decided,
All
after  effluent
Biodegradability
EN ISO 9888
activities  /  characterisatio
Current
processes
n (5)
text in D1:
EN
standard  Finishing
available  for  some
Brominated
flame
with
Once
every
polybrominated
retardants (1)
flame
3 months
diphenyl
ethers  retardants
0
(i.e. EN 16694)
All
Chemical
oxygen  No  EN  standard
Once
every
activities  /
demand (COD) (2)(3)
available
month
processes
Once
every
Colour
EN ISO 7887
Dyeing
month
All
Hydrocarbon  oil  index
Once
every
EN ISO 9377-2
activities  /
(HOI)
3 months
processes
Pre-
treatment
and/or
dyeing  of
Various EN

polyester
standards available
Metals
Antimony
Finishing
Once
every
(e.g. EN ISO 1188
/
(Sb)
with
month
5, EN ISO 17294-2
metalloids
flame
or EN ISO 15586)
retardants
using
antimony
trioxide
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Background paper – Final meeting for the review of the TXT BREF
Dyeing
with
Chromium
chromium
(Cr)
-
containing
dyes
Copper
All
(Cu)
activities  /
Nickel (Ni)
processes
Zinc (Zn)
Dyeing
with  dyes
Hexavalent
EN ISO 10304-3
containing  Once
every
chromium
or EN ISO 23913
hexavalen
month
(Cr(VI))
t
chromium
EN
standards  Pre-
available  for  some  treatment
pesticides
(e.g.  of
raw  Once
every
Pesticides (1)
EN 12918,
EN  wool
3 months
16693  or  EN  ISO  fibres  by
27108)
scouring
All
Perfluorinated
No  EN  standard
Once
every
activities  /
compounds (1)
available
3 months
processes
Dyeing
Sulphide,
easily  No  EN  standard  with
Once
every
released (S2-)
available
sulphur
3 months
dyes
EN
standard
available
for
Once
every
Surfactants
anionic  surfactants
3 months
(i.e. EN 903)
EN 12260 or
Once
every
Total nitrogen (TN) (2)  EN ISO 11905-1
month
Total  organic  carbon
Once
every
EN 1484
(TOC) (2) (3)
month
EN ISO 6878,
EN ISO 15681-1,
Once
every
Total phosphorus (TP)
EN ISO 15681-2
month
or EN ISO 11885
Total suspended solids
Once
every
EN 872
(TSS) (2)
month
Fish
eggs
All
(Danio
EN ISO 15088
activities  /
rerio)
processes
Daphnia
(Daphnia
EN ISO 6341
magna
To  be  decided
Straus)
based on a risk
Luminescen
EN ISO 11348-1,
Toxicit
assessment,
t bacteria
EN ISO 11348-2
y (4)
after  effluent
(Vibrio
or EN ISO 11348-
characterisatio
fischeri)
3
n (5)
Duckweed
EN ISO 20079 or
(Lemna
EN ISO 20227
minor)
EN ISO 8692,
Algae
EN ISO 10253 or
EN ISO 10710
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(1)  The  monitoring  only  applies  when  the  substance(s)/parameter,  including  groups  of
substances or individual substances in a group of substances, concerned is identified
as  relevant  in  the  waste  water  stream  based  on  the  inventory  of  inputs  and  outputs
mentioned in BAT 2.
(2)  The  monitoring  only  applies  in  the  case  of  a  direct  discharge  to  a  receiving  water
body.
(3)  TOC  monitoring  and  COD  monitoring  are  alternatives.  TOC  monitoring  is  the
preferred option because it does not rely on the use of very toxic compounds.
(4) An appropriate combination of the toxicity parameters can be used.
(5)  The  effluent  characterisation  is  carried  out  before  starting  operation  of  the  plant  or
before a permit for the plant is updated for the first time after the publication of these
BAT conclusions, and after each significant change in the plant.

BAT statement
  Amend the BAT statement as follows: “BAT is to monitor relevant emissions to water
with at least …”, as only pollutants at detectable concentrations should be monitored,
not all the pollutants listed in the table (CZ_A 7, CZ_B 84).
  Allow the possibility for self-monitoring by the operator (DE 253).
  Clarify that the measurement is done at the point of release (DE 286, EURATEX 32).
  Add monitoring/measurement points in raw waste water or after intermediate treatment
steps to determine treatment efficiencies of WWTP (DE 142).

Standard(s)
  Allow the possibility to use the standards set in "Standard Methods for the examination
of water and wastewater", when no EN or ISO standard is available (ES 35).
  Allow equivalent standards to EN standards when self-monitoring (DE 254).

Activities / processes
  Modify  the  heading  of  the  table  as  follows:  “Activities  /  processes  if  relevant”
(EURATEX 32).

Monitoring frequency
  Change  for  all  parameters  the  minimum  monitoring  frequency  to  once  every  three
months  (EURATEX 32,  EURATEX 36,  EURATEX 145)  to  avoid  additional  testing
costs.
  Change the monitoring frequency based on a risk-based sampling frequency dependent
Summary
on the amount and nature of the emission (UK 9).
of

comments:  Adsorbable organically bound halogens (AOX)
  Change relevant processes to “pre-treatment of synthetic knitwear” (DE 351).
  Support the proposed monitoring frequency once every month. (DE 127).
  Reduce the monitoring frequency from once every month to once every three months
(EURATEX 146), as in most European countries the monitoring frequency is not lower
than every three months.

Alkylphenols and alkylphenol ethoxylates
  Clarify  which specific  alkylphenol ethoxylates (mono, di  or poly)  are  monitored and
with which method(s) (BE 4).
  Support the proposed monitoring frequency once every 3 months (DE 127).
  Change relevant processes to “pre-treatment of synthetic knitwear” (DE 351).

Biochemical oxygen demand (BODn)
  Replace  EN  1899-1  by  EN  ISO  5815-1,  which  is  the  applied  standard  since  2019
(BE 5, FR_A 29).
  Increase  monitoring  frequency  from  once  every  month  to  once  every  week,  as  these
measurements are necessary for the operation of waste water treatment plants (DE 127,
SE 10).
  Change relevant processes to “pre-treatment of synthetic knitwear” (DE 351).

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Background paper – Final meeting for the review of the TXT BREF
Biodegradability
  Clarify that monitoring only applies for indirect discharges. It is not useful to monitor
biodegradability of effluents that have already passed a biological treatment (BE 23).
  Include  that  the  monitoring  can  apply  to  other  monitoring  points,  e.g.  partial
streams/concentrates from relevant processes. Measurements at the point of release are
not sufficient as hardly biodegradable substances might be diluted (DE 340).

Brominated flame retardants
  Support the proposed monitoring frequency of once every 3 months (DE 127).

Chemical oxygen demand (COD)
  Increase the monitoring frequency from once every month to once every week (SE 10),
or  to  daily  (DE 127),  as  these  measurements  are  necessary  for  the  operation  of  waste
water treatment plants.

Colour
  Increase  the  monitoring  frequency  from  once  every  month  to  daily,  as  these
measurements  are  necessary  for  the  operation  of  waste  water  treatment  plants
(DE 127).
  Replace EN ISO 7887 by SCA blue book 103 ISBN 0117519533 Absorbance Scan  -
determined  by  scanning  UV/  visible  spectrometry  (measured  in  absorbance  units),  as
EN 7887 is suitable for colours of drinking water, not so much for the textile effluents
(UK 48).

Hydrocarbon oil index (HOI)
  Increase  the  monitoring  frequency  from  once  every  3  months  to  once  every  month
(DE 127).
  Change relevant processes to “Processing of man-made fibres and its mixtures of goods
and knitwear good” (CZ_A 4, CZ_B 85).
  Change relevant processes to “pre-treatment of synthetic knitwear” (DE 351).

Metals / metalloids: Chromium (Cr)
  Change  relevant  processes  to  “Dyeing  /  printing”  (CZ_A 5,  CZ_B 86),  as  Cr  is  only
present when using metal-complex dyes containing such metal.
  Support the proposed monitoring frequency of once every month (DE 127).

Metals / metalloids: Copper (Cu)
  Change relevant processes to “Dyeing” (DE 344, EURATEX 32).
  Change  relevant processes to “Dyeing / printing”  (CZ_A 5, CZ_B 86), as Cu is only
present when using metal-complex dyes containing such metal.
  Support the proposed monitoring frequency of once every month. (DE 127).

Metals / metalloids: Nickel (Ni)
  Change relevant processes to “Dyeing” (DE 344, EURATEX 32).
  Change  relevant  processes  to  “Dyeing  /  printing”  (CZ_A 5,  CZ_B 86),  as  Ni  is  only
present when using metal-complex dyes containing such metal.
  Support the proposed monitoring frequency of once every month (DE 127).

Metals / metalloids: Hexavalent chromium (Cr(VI)
  EN  ISO  10304-3 is preferred as EN  ISO  23913: 2009 does not allow the elimination
of potential interference unless a pre-treatment step is performed (BE 6).
  Support the proposed monitoring frequency of once every month (DE 127).

Metals / metalloids: Zinc (Zn)
  Change relevant processes to “Dyeing” (EURATEX 32).
  Change  relevant processes to “Dyeing / printing” (CZ_A 5, CZ_B 86), as Zn is only
present when using metal-complex dyes containing such metal.
  Support the proposed monitoring frequency of once every month (DE 127).

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Pesticides
  Reduce  the  monitoring  frequency  from  once  every  three  months  to  once  every  six
months.  In  pre-treatment  of  raw  wool  fibres  by  scouring,  pesticides  might  be  only
indirect occurrences (i.e. impurities) (IT 9).
  Support the proposed monitoring frequency of once every 3 months (DE 127).

Perfluorinated compounds
  Add the following monitoring methods: ISO 25101 (PFOA and PFOS) and ISO 21675
(extensive range of PFAS) (BE 7).
  Change the name of the parameter to Per- and Polyfluorinated compounds (DE 352).
  Change relevant processes to “Finishing” (DE 352, EURATEX 32).

Sulphide, easily released (S2-)
  Increase  the  monitoring  frequency  from  once  every  3  months  to  once  every  month
(DE 127).
  Add in relevant processes “wool scouring” (UK 11).
  Add the following monitoring method: methylene blue (UK 11).

Surfactants
  Clarify  that  the  3  groups  of  surfactants  (anionic,  cationic  and  non-ionic)  must  be
monitored (BE 25).
  Clarify which standard to use for monitoring non-anionic surfactants (FR_A 25).
  Delete monitoring of hardly biodegradable surfactants, and address this issue in BAT
16, as hardly biodegradable surfactants should not be used (DE 143).
  Delete  the  monitoring  of  surfactants.  Surfactants  are  regulated  by  “EU  detergents
directive”  (EURATEX 32),  and  the  measurement  standards  are  not  available
(EURATEX 147).

Total nitrogen (TN)
  Increase the monitoring frequency from once every month to once every week, as these
measurements are necessary for the operation of waste water treatment plants (DE 127,
SE 10).
  Reduce the monitoring frequency from once every month to once every three months.
Monthly frequency does not add value for the company or the authorities, so additional
testing costs should be avoided (EURATEX 37).

Total organic carbon (TOC)
  Increase the monitoring frequency from once every month to once every week (SE 10),
or  to  daily  (DE 127),  as  these  measurements  are  necessary  for  the  operation  of  waste
water treatment plants.

Total phosphorus (TP)
  Replace  EN ISO 6878  with  ICP-AES  or  ICP-MS  techniques,  as  spectrophotometric
methods can lead to an underestimation of the actual value (BE 8).
  Increase the monitoring frequency from once every month to once every week, as these
measurements are necessary for the operation of waste water treatment plants (DE 127,
SE 10).
  Reduce the monitoring frequency from once every month to once every three months.
Monthly frequency does not add value for the company or the authorities, so additional
testing costs should be avoided (EURATEX 38).

Total suspended solids (TSS)
  Increase the monitoring frequency from once every month to once every week (SE 10),
or  to  daily  (DE 127),  as  these  measurements  are  necessary  for  the  operation  of  waste
water treatment plants.

Toxicity
  Modify the monitoring frequency to once every month. Different hazardous chemicals
can be used in the textile industry (DE 127).
  Modify  the  monitoring  frequency  as  follows:  “To  be  decided,  after  effluent
characterisation” (AT 37).
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Background paper – Final meeting for the review of the TXT BREF
Additional parameters
  Add  the  following  parameters:  NH4-N,  pH  and  temperature.  NH4-N  has  a  negative
impact on water bodies (toxic for fish), while pH and temperature contribute to follow
the impact on water bodies (DE 148).

Footnote (1)
  Add HOI (EURATEX 32, EURATEX 147), as HOI is only present in pretreatment of
synthetic knitwear (DE 163).
  Add  all  metalloids  (EURATEX 32,  EURATEX 147),  except  for  zinc,  as  they  are
present in specific processes only (DE 164).
  Add sulphides as they are not relevant in all processes (DE 390).
  Add surfactants (EURATEX 147).

Footnote (2)
  Add  the  following  parameters:  biodegradability  (EURATEX 32,  EURATEX 147),
colour
(DE 161,
EURATEX 32,
EURATEX 33,
EURATEX 147),
HOI
(EURATEX 32,  EURATEX 35,  EURATEX 147),  TP  (CZ_A 6,  CZ_B 88,  DE 128,
EURATEX 32,  EURATEX 147,)  and  toxicity  (BE 24,  DE 168,  EURATEX 32,
EURATEX 147).
  Modify  the  footnote  to  include  monitoring  when  waste  water  is  treated  by  a
downstream WWTP (FR_A 64).
  Delete  Footnote  (2).  It  is  important  to  monitor  these  parameters  as  they  affect  the
downstream WWTP (SE 45).

Footnote (4)
  Amend the footnote to: “One or an appropriate combination of the toxicity parameters
can be used”, as one test might be sufficient (DE 353).
  Add  a  risk  assessment  as  a  criteria  to  determine  which  combination  of  the  toxicity
parameters is appropriate (AT 37).
  Amend the footnote to require monitoring toxicity only when other parameters or tests
indicate that  it  will be  useful  (e.g. biodegradability), and add one flora and one  fauna
test as a minimum to provide more consistent and comparable results (UK 12).

Footnote (5)
  Clarify what a significant change is (DE 388, DE 389).
  Maintain the footnote but amend the wording as follows: “the effluent characterisation
is carried out before starting operation of the plant or for existing plants, within 1 year
after  the  publication  of  these  BAT  conclusions,  and  after  each  change  that  may
negatively affect the quantity and qualitative characteristics of the waste water streams
pursuant  to  BAT  2”.  This  would  clarify  what  “significant  changes”  mean  (EEB 173,
EEB 174).

Additional footnote
  Add  a  minimum  monitoring  frequency  of  yearly  for  periodical  measurements,  if
emission levels are significantly stable (EURATEX 39).
  Apply  monitoring  for  metals  only  when  the  metal  is  identified  as  relevant  in  the
integrated permit (in case of direct discharge) or in the agreement with the WWTP (in
case of indirect discharge) (CZ_A 5, CZ_B 86).
  Reduce or remove monitoring of AOX, COD and biodegradability, if toxicity tests are
carried  out,  in  order  to  avoid  the  risk  of  duplication  or  overlap  of  the  monitoring
parameters with the same degree of information (UK 10).
  Amend  the  footnote  to  increase  the  monitoring  frequency  to  daily  when  synthetic
textiles or UV-treatment activities are carried out (EEB 172).

BAT statement
  Footnote  (1)  gives  the  flexibility  to  monitor  only  those  parameters  that  have  been
EIPPCB
identified  in  the  inventory  of  inputs  and  outputs.  It  does  not  seem  necessary  to  repeat
assessment
this in the BAT statement, which is a standard text used in all recently published BAT
:
conclusions.
  Determining  which  laboratory  (internal  or  external)  carries  out  the  monitoring  is  an
implementation issue.
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  According to IED Article 15, “the emission limit values shall apply at the point where
the emissions leaves the installation”, which implies that the monitoring is carried out at
the same location. This could be clarified by recalling this provision of  IED Article 15
in the “General considerations”.
  According to the “Monitoring associated with” column of the table included in BAT 7,
the aim of BAT 7 is to propose a monitoring frequency when a BAT-AEL is proposed,
and  for  parameters  considered  KEIs.  Therefore,  the  aim  of  BAT 7  is  not  to  determine
the treatment efficiencies of the techniques applied.

Standard(s)
  When there is no EN standard available, it is possible to use ISO standards or any other
standards  (e.g.  “Standard  Methods  for  the  examination  of  water  and  wastewater”)  if
they  ensure  the  provision  of  data  of  an  equivalent  scientific  quality.  This  is  already
mentioned in the BAT statement.

Activities / processes
  The specific processes relevant to emissions to water of each parameter have  already
been identified in the KoM conclusions and the data analysis and are listed in the table
of BAT 7. Therefore, a general statement such as “if relevant” is not needed.

Monitoring frequency
  BAT 7 aims at setting the  minimum  monitoring frequency and is based on the  TXT
data collection and the environmental risk and performance achievable by using BAT.
The  data  collection  encompasses  real  cases  and  therefore  accounts  for  specific
conditions on the amount and nature of the emissions, and the costs of measurements.
  Information  on  207  monitoring  frequencies  were  reported  for  115  emission  points.
Because  different  monitoring  parameters  require  different  monitoring  frequencies,  on
average  2  different  frequencies  were  reported  per  emission  point.  Out  of  these  207
monitoring frequencies, 31 emission points reported yearly, 41 twice per year, 35  four
times per year, 31 monthly, 8 weekly, 6 daily and the rest Other or No information. The
most  commonly  set  frequencies  for  direct  discharge  were  monthly  (14  out  of  25
emission  points),  and  for  indirect  discharge  twice  per  year  (36  out  of  91  emission
points).
  The  type  of  discharge  (i.e.  direct)  has  a  strong  influence  on  the  requirement  for  a
monthly  or  quarterly  monitoring  frequency  (e.g.  used  2-3  times  more  often  for  direct
compared  to  indirect  discharge).  This  could  be  reflected  for  the  parameters  with  a
monthly frequency ( AOX, BOD, COD, colour, metals (Sb, Cr, Cu, Ni, Zn), TN, TOC,
TP and TSS ) or quarterly frequency (HOI, sulphide, other surfactants) in the flexibility
to  increase  the  minimum  monitoring  frequency  for  indirect  discharge  providing  the
downstream waste water treatment plant abates the pollutants concerned.

Adsorbable organically bound halogens (AOX)
  According to data collected, AOX is monitored in plants  carrying out  many different
processes.  Apart  from  washing  the  synthetic  fibre  or  knitwear,  AOX  may  originate
from  bleaching  (e.g.  if  using  sodium  hypochlorite  or  sodium  chlorite),  from  finishing
(e.g.  if  using  brominated  flame  retardants  or  shrink-proofing  (Hercosett))  or  dyeing
(e.g.  dyeing  with  some  vat  dyes).  Therefore,  limiting  it  only  to  "pre-treatment  of
synthetic  knitwear"  would  potentially  increase  the  environmental  risk  and  impact  of
those plants/treatments.
  Out  of  60  emission  points  reporting  AOX  emissions  to  water,  13  are  connected  to
direct  discharge  and  47  to  indirect  discharge..  The  most  common  frequency  reported
for direct discharge is monthly (5 emission points) and for indirect discharge four times
per year (15 emission points).
  The  monthly  monitoring frequency  seems reasonable  due  to  wide  fluctuations (min.-
max.  range)  in  the  emissions  profile.  However,  a  footnote  indicating  the  reduction  of
monitoring frequencies in the case of indirect discharge could be added.

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Alkylphenols and alkylphenol ethoxylates
  The alkylphenol ethoxylates that can be monitored under this parameter are those listed
in  standards  EN  ISO  18857-1  (e.g.  mixture  of  4-nonylphenol  isomers)  and  18857-2
(OP, OP1EO, OP2EO, NP, NP1EO, NP2EO)5.
  Regarding  setting  "pre-treatment  of  knitwear"  as  the  only  relevant  process,  see  the
assessment in AOX above.
  As alkylphenols and alkylphenol ethoxylates are  non-ionic surfactants,  they  could be
moved to the section on surfactants.

Biochemical oxygen demand (BODn)
  There is indeed a new standard, EN ISO 5815-1, for monitoring BODn which could be
mentioned.
  According to the data collection, out of 85 reported BODn data sets, 4 reported weekly
and 1 daily monitoring frequency. According to the ROM and the existing TXT BREF,
BOD5,  COD/TOC,  Colour,  TN,  TP  or  TSS  are  common  parameters  measured  for
controlling the operation of the biological waste water treatment in the textile sector.
  Regarding  setting  "pre-treatment  of  knitwear"  as  the  only  relevant  process,  see  the
assessment in AOX above.

Biodegradability
  The  monitoring  of  biodegradability  of  the  effluent  could  be  a  valuable  parameter  to
control the environmental impact of both direct and indirect discharges. Only  two data
sets for indirect discharge (SE119 and SE120) were reported in the data collection.
  The  characteristics  of  individual  waste  water  streams  are  addressed  in  BAT 2,
including their bioeliminability. Biodegradability could be another factor to consider in
BAT 6.

Chemical oxygen demand (COD)
  BAT 7 aims to set the minimum monitoring frequency which can be increased in the
implementation. According to the data collection, out of 97 COD data sets, 6 reported
weekly  monitoring  and  5  a  daily  monitoring  frequency.  Therefore,  the  proposal  does
not seem to be supported by the data collection.

Colour
  BAT 7 aims to set the minimum monitoring frequency, which can be increased in the
implementation.  In  the  data  collection,  out  of  22  plants  reported  data  sets,  only  2
reported  a  daily  monitoring  frequency.  Therefore,  the  proposal  does  not  seem  to  be
supported by the data collection.
  In  the  scope  of  EN  ISO  7887,  it  is  indicated  that  Method  B  (use  of
(spectro)photometer)  is  appropriate  for  industrial  water  with  little  colour.  Methods  C
and  D  (based  on  hexachloroplatinate  concentration)  are  suitable  for  assessment  of
water colour in water treatment plants. The method in the SCA blue book seems to be
similar to Method B from EN ISO 7887.

Hydrocarbon oil index (HOI)
  Based on the data collection, only 2 out of  the 34 emission points that reported HOI
emissions to water measure HOI monthly. Therefore, the proposal does not seem to be
supported by the data collection.
  20  plants  out  of  the  30  plants  that  reported  HOI  emissions  to  water  do  not  treat
knitwear or wash synthetic fibres.
  It seems reasonable to add Footnote (1) to HOI, as indeed it may be relevant only for
certain preparations, auxiliaries or incoming fibres.

Metals / metalloids: Chromium (Cr)
  Metal-complex dyes  may contain chromium. This could be clarified  by adding metal
oxide dyes as an example of chromium-containing dyes in activity/process.


5 4-(1,1,3,3-tetramethylbutyl)phenol (OP), and its mono- (OP1EO) and diethoxylate (OP2EO), 4-nonylphenol (mixture of isomers)
(NP), and its mono- (NP1EO) and diethoxylate (NP2EO)
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Metals / metalloids: Copper (Cu)
  According to the data collection, 82 plants report 89 data sets for emissions of copper;
of these, 70 data sets are for dyeing and 15 data sets for printing processes. 13 plants do
both  processes  (e.g.  BE008,  DE025,  DE049,  ES058,  FR131)  and  Plant  BE009  only
does  printing.  The  relevant  processes  to  monitor  this  parameter  seem  to  be  “Dyeing”
and “Printing with dyes”, due to use of dyes containing this metal.

Metals / metalloids: Nickel (Ni)
  According to the data collection, 60 plants report 65 data sets for emissions of nickel;
of these, 53 data sets are for dyeing and 14 data sets for printing process. 11 plants do
both processes (e.g. BE008, DE025, DE032, DE049, ES058, FR131) and Plant BE009
only  does  printing.  The  relevant  processes  to  monitor  this  parameter  seem  to  be
“Dyeing” and “Printing with dyes”, due to use of dyes containing this metal.

Metals / metalloids: Hexavalent chromium (Cr(VI)
  In EN ISO 23913:2009 in Section “4 Interferences”, it is hinted that reducing agents,
oxidising agents (like peroxacetic acid, or permanganate), strong alkalinity, colours or
turbidity  in  the  sample  may  lead  to  biases  and  interfere  with  chromium  (VI)
determination.  The  procedures  (either  analytic,  interpretative  or  calculations)  to
accommodate for these interferences are explained in the standard. For strong alkaline
samples,  pretreatment  with  acids  (HCl,  H2SO4)  may  be  needed.  EN  ISO  23913  is
preferred  over  EN  ISO  10304-3  because  it  is  more  specific  for  this  pollutant,  more
precise (LoD), and has less uncertainty.
  The same standards are used in other BAT conclusions (e.g. WT, STS).

Metals / metalloids: Zinc (Zn)
  According to the data collection, 80 plants report 88 data sets for emissions of zinc to
water; of these, 71 plants report carrying out dyeing and 9 plants do not report dyeing,
but other pre-treatment processes, printing  (15 data sets) and coating (AT004, BE009,
BE013,  FR135,  IT061,  IT069,  IT074,  IT076,  IT079).  The  relevant  processes  seem  to
be  “All  processes”  because  the  source  can  be  also  raw  material  (viscose  fibres),
cationic dyes and bleaching (Zn added to start chemical reaction).

Pesticides
  BAT 4a requires the operator to control the level of ectoparasiticides on the incoming
textile  material  (e.g.  raw  wool),  because  they  can  be  the  source  of  these  pollutants  in
the effluent.
  A  total  of  13  data  sets  were  provided,  with  5  emission  points/plants  (IT076,  IT092,
IT097,  UK128,  UK129).  2  plants  from  UK  (6  data  sets)  measure  every  3  months;  IT
plants report ‘Other’ frequency.

Perfluorinated compounds
  The list of standards is given in a similar way as in all other BAT conclusions. The use
of  EN  standards  guarantees  the  scientific  quality  and  comparability  of  the
measurements.
  In  addition,  Table  3.2  of  D1  includes  the  monitoring  standards  reported  in  the  data
collection for PFOA, PFOS and PFAS.
  To  provide  more  information  about  the  monitoring  standards  for  PFOA,  PFOS  and
PFAS, ISO 25101 and ISO 21675 can be mentioned in  Section 3 of the review of  the
TXT BREF.
  Regarding the name to identify perfluorinated compounds (PFCs), the OECD refers to
PFCs using the abbreviation PFASs (per and polyfluoroalkyl substances). According to
the  document  published  by  the  OECD6  in  2013  named:  ‘Synthesis  paper  on  Per-  and
Polyfluorinated Chemicals (PFCS)’, in the past, PFASs (chemicals that contain one or
more  perfluoroalkyl  moieties,  –CnF2n+1)  were  often  referred  to  as  “PFCs”  (per-  and

6 https://www.oecd.org/chemicalsafety/risk-management/synthesis-paper-on-per-and-polyfluorinated-chemicals.htm
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Background paper – Final meeting for the review of the TXT BREF
polyfluorinated chemicals), but this term can also be understood as perfluorocarbons.
  The Stockholm Convention7 only includes perfluorooctanoic acid (PFOA), its salts and
PFOA-related compounds.
  Table  3.2  of  D1  of  the  TXT  BREF  shows  all  the  compounds  reported  as
perfluorocarbons  in  the  questionnaires,  where  more  than  8  different  compounds  were
identified,  e.g.  per-  and  polyfluoroalkyl  substances,  perfluorobutanoic  acid,
perfluorodecanoic acid.
  Taking into account the above bullet points related to the  different names to identify
perfluorocarbons  compounds,  it  seems  appropriate  to  use  the  internationally  accepted
name, proposed by the OECD and which includes a wide range of chemical compounds
consisting of carbon and fluorine.
  Not only are finishing processes identified as a source of emissions to water of PFCs.
According  to  the  data  collection,  there  are  different  associated  processes  where  PFCs
have  been  reported,  e.g.  dyeing,  shrink-proof  finishing,  printing,  washing  synthetic
fibre,  desizing,  bleaching,  coating.  It  is  not  clear  if  they  are  already  present  in  the
incoming material.
  In addition, footnote (1) gives the flexibility to monitor only when PFCs are identified
as relevant in the inventory of inputs and outputs in BAT 2.

Sulphide, easily released (S2-)
  According  to  the  data  collection,  3  out  of  19  emission  points  reported  a  monthly
monitoring  frequency.  Therefore,  the  proposal  does  not  seem  to  be  supported  by  the
data collection.
  According to the KoM conclusions, it was decided that sulphides were to be considered
a KEI for dyeing with sulphide dyes.
  Currently there is no EN standard for monitoring sulphide in emissions to water. The
ISO  10530:1992  or  ISO  13358:1997  standards  using  methylene  blue  could  be
mentioned in the BREF.

Surfactants
  The  wording  of  the  parameter  (‘Surfactants’)  is  generic  and  enables  the  competent
authority to specify the monitoring of the group or individual surfactants, based on the
inventory and relevance as related to BAT 2.
  The only available EN standard at the time of drafting  the document was EN 903 for
anionic surfactants. The  national  standards reported to be used for  various surfactants
are given in Table 3.5 of D1.
  No  specific  surfactants  (e.g.  like  hardly  biodegradable)  are  singled  out  in  BAT 7.
BAT 16a  is  not  related  to  monitoring,  but  deals  with  substitution  of  surfactants  like
AP/APEO with biodegradable ones.
  A  total  of  36  emission  points  reported  96  data  sets,  proving  that  monitoring  of
surfactants  in  the  effluents  is  important  in  the  textile  sector.  If  EN  standards  are  not
available, BAT is to use ISO, national or other international standards that ensure the
provision of data of an equivalent scientific quality. The national standards reported to
be used for various surfactants are given in Table 3.5 of D1.

Total nitrogen (TN)
  BAT  7  aims  at  setting  the  minimum  monitoring  frequency  and  is  based  on  the  data
collection, which encompasses real cases.
  A total of 8 out of 18 emission points with direct discharge to water are monitored once
every  month.  On  the  other  hand,  no  emission  points  are  monitored  either  once  every
week or once every three months. This shows that the data collection does not support
the proposed changes.
  The  aim  of  BAT  7  is  not  to  set  a  monitoring  frequency  to  check  the  maintenance
operations of waste water treatment plants.

Total organic carbon (TOC)
  BAT 7 aims to set the minimum monitoring frequency, which can be increased in the
implementation phase.

7 http://www.pops.int/TheConvention/ThePOPs/AllPOPs/tabid/2509/Default.aspx
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  According  to  the  data  collection,  none  of  the  21  TOC  data  sets  reported  a  weekly
monitoring  frequency.  This  shows  that  the  data  collection  does  not  support  the
proposed changes.

Total phosphorus (TP)
  EN ISO 6878 is included in Annex 2 “Standards for the measurement of emissions to
water” of the ROM as a Standard Method for total phosphorus (TP).
  The interferences affecting the accuracy of measurements for each standard are usually
described  in  its  annexes  or  in  a  specific  section.  As  these  interferences  are  clearly
identified in each standard, there is no reason to exclude the standard.
  Among the standards in BAT 7 is included EN ISO 11885:2009 by ICP-OES.
  A monitoring frequency of once every week fulfils the minimum monitoring frequency
proposed of once every  month. It is  in the domain  of the competent authority  to set a
stricter monitoring frequency.
  The  aim  of  BAT  7  is  not  to  set  a  monitoring  frequency  to  check  the  maintenance
operations of waste water treatment plants.
  According  to  the  TXT  data  collection,  the  most  common  monitoring  frequency,  for
direct  and  indirect  discharges,  is  monthly  (14  out  of  58  emission  points  to  water),
followed by  four times per  year (10 out of 58 emission points to  water each of them)
and twice a year (9 out of 58 emission points to water each of them).

Total suspended solids (TSS)
  BAT 7 aims to set the minimum monitoring frequency, which can be increased in the
implementation phase.
  According to the data collection, out of 87 TSS data sets, 4 reported daily monitoring
and  4  a  weekly  monitoring  frequency.  Therefore,  the  proposal  does  not  seem  to  be
supported by the data collection.

Toxicity
  According  to  the  data  collection,  toxicity  was  reported  from  3  indirect  discharge
emission  points  (10  data  sets)  and  10  direct  discharge  emission  points  (35  data  sets).
Footnote  (5)  requires  the  competent  authority  to  decide  on  the  monitoring  frequency
(relevance) based on a risk assessment, after effluent characterisation, including in this
assessment  the  ability  of  the  downstream  waste  water  treatment  to  abate  toxic
compounds.
  The frequency of toxicity monitoring may be based on the information on the specific
toxic  chemicals  whose  relevance  is  determined  in  the  inventory  of  inputs  and  outputs
from BAT 2.
  It is not clear why the wording “based on a risk assessment” should be omitted.

Additional parameters
  The monitoring of pH and temperature as key parameters of the waste water streams is
set  in  BAT 6.  According  to  the  ROM,  NH4-N  is  usually  measured  to  control  the
nitrification  step  of  a  biological  waste  water  treatment  plant  or  to  control  the  effluent
toxicity  and  is  therefore  an  important  parameter  for  the  good  operation  of  the  waste
water treatment plant.
  However, the TWG did not conclude at the Kick-off Meeting to consider NH4-N as a
KEI. In recent BAT conclusions, there is a tendency not to define monitoring and BAT-
AELs for NH4-N, but rather  to use  it to assess the performance of a biological  waste
water treatment plant. Instead, BAT-AELs and monitoring for total nitrogen (TN) were
proposed, as this parameter better reflects the eutrophication potential.

Footnote (1)
  The HOI parameter can be present in the effluents of pretreatment of synthetic knitwear
or washing of synthetic fibres.
  Footnote  (1) is not deemed necessary  for  metalloids or sulphides since the  processes
relevant for their monitoring are already indicated in BAT 7.
  Because  surfactants  are  widely  used  in  many  pretreatment  and  washing  processes  or
because they are added as a component to many other preparations used in textile wet
treatments, adding Footnote (1) to surfactants seems unnecessary.

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Footnote (2)
  It  is  not  clear  why  biodegradability  would  be  monitored  only  for  direct  discharges,
since (only) 2 data sets were reported and they were for indirect discharge. In addition,
the  monitoring  frequency  for  biodegradability  and  toxicity  will  be  decided  based  on
effluent  characterisation,  according  to  Footnote  (5).  Similarly,  for  colour  (15  plants
reported  data,  5  of  them  with  indirect  discharge),  HOI  (90  plants  reported  data,  68
reported  indirect  discharge),  Total  P  (59  plants  reported  data,  38  reported  indirect
discharge)  and  toxicity  (13  plants  reported  data,  3  reported  indirect  discharge),  plants
that  report  indirect  discharge  reported  monitoring  these  parameters.  According  to  the
data collection, these parameters (biodegradability, colour,  HOI, Total P and toxicity)
are monitored for indirect discharges as well.
  For  the  issue  of  toxicity  monitoring  for  indirect  discharge  only,  see  the  assessment
under Toxicity above.
  A BAT-AEL for HOI is proposed for indirect discharge.
  It  is  important  to  know  whether  the  effluent  discharged  indirectly,  to  be  treated  in  a
downstream  waste  water  treatment  plant,  contains  non-biodegradable  and  toxic
compounds (e.g. the qualitative parameter colour is often used where dyes are present
in  the  effluent,  as  they  can  be  non-biodegradable  and/or  toxic).  It  is  not  clear  why
plants discharging indirectly would not need to monitor these parameters.
  Footnote (2) could be replaced by footnote (6), since it is important to  monitor these
parameters  before  they  are  abated  in  the  downstream  WWTP  (e.g.  COD/TOC,  BOD,
TSS and Total N) to protect its performance/operation.

Footnote (4)
  Indeed,  the  competent  authority  may  conclude  that  one  test  could  be  sufficient  and
Footnote (4) could be amended accordingly.
  The  decision  on  a  combination  of  toxicity  tests  is  in  the  domain  of  the  competent
authority due to local circumstances and national and EU  legislation pertaining to the
environmental quality standards of the particular water body.
   The competent authority is free to decide on the method or combination of methods to
be  used,  taking  into  account  various  aspects  (e.g.  the  biodegradability,  and  flora  and
fauna tests). Keeping the text generic, without making a combination of flora and fauna
methods  compulsory,  seems  to  give  more  flexibility  and  accommodate  more  possible
outcomes.

Footnote (5)
  Significant change is any change that can significantly affect the characteristics of the
waste water and that would therefore require a new assessment of these characteristics.
  The wording “significant change” used in the footnote may be clarified by replacing it
with a description, e.g. “change that may negatively affect the quantity and qualitative
characteristics of the waste water streams pursuant to BAT 2”.

Additional footnote
  Effluents of the textile sector can fluctuate and change a lot, based on the production
demands.  This  is  particularly  true  for  plants  working  on  commission.  Therefore,  a
footnote on decreasing the minimum monitoring frequency in the case where emission
levels are stable does not seem relevant..
  Monitoring of emissions of metals to water is carried out for the processes where they
have  the  potential  to  occur  (e.g.  dyeing),  as  specified  in  the  “Activities/processes”
column of the table.
  Although  toxicity  provides  similar  information  to  AOX,  COD  and  biodegradability,
these  parameters  on  their  own  give  more  specific  information  on  the  presence  and
characteristics  of  certain  hazardous  compounds  or  groups  of  compounds  that  are
available from the toxicity test of the effluent. The information provided may ‘overlap’
in  the  sense  that  the  parameters  mentioned  would  all  detect  the  same  effect  of  the
pollutants/compounds (e.g.  the  toxicity), but the identity and concentration of  specific
compounds  or  groups  of  compounds  causing  the  toxicity    (important  for  their
abatement) would be missing.
  Only  one  plant  (CZ015)  reported  adding  UV  stabilisers  in  dyeing.  No  additional
information  regarding  UV  treatments  was  received  in  the  data  collection  via
questionnaires, to support the comment and assess the influence of UV treatment on the
monitoring frequency.
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  According  to  the  data  collected,  there  is  no  significant  difference  in  the  monitoring
frequency  between  plants  treating  synthetic  fibres  versus  plants  treating  other  fibres.
The type of discharge (i.e. direct) has a much bigger influence on the requirement for a
monthly  monitoring  frequency  (e.g.  used  2-3  times  more  often  compared  to  indirect
discharge).
BAT statement
  To add in General considerations a provision that the emission levels associated with
the BAT-AELs for emissions to water apply at the point where the emission leaves the
installation.

Activities / processes
  To change  activities/processes for copper, nickel  and zinc to “Dyeing”  and  “Printing
with dyes”.

Monitoring frequency
  To add new footnotes to clarify the adaptation of monthly monitoring frequency (for
the parameters  AOX, BOD,  COD, colour,  metals (Sb, Cr, Cu, Ni,  Zn), TN, TOC, TP
and TSS), and quarterly monitoring frequency (for the parameters HOI, sulphide, other
surfactants) in the case of indirect discharge.

Adsorbable organically bound halogens (AOX)
  To clarify the adaptation of monitoring frequencies in the case of indirect discharge.

Biodegradability
  To add biodegradability as a factor to be considered for individual waste water streams
in BAT 2.

Biochemical oxygen demand (BODn)
  To add a new standard, EN ISO 5815-1.

Hydrocarbon oil index (HOI)
  To add Footnote (1).
EIPPCB

proposal:
Metals / metalloids:

Chromium (Cr)
  To  add  metal  oxide  dyes  as  an  example  of  chromium-containing  dyes  in
activity/process.

Copper (Cu)
  To specify dyeing/printing as concerned processes

Nickel (Ni)
  To specify dyeing/printing as concerned processes

Pesticides
  To  change  the  frequency  to  be  decided  after  effluent  characterisation  (same  as
biodegradability).

Perfluorinated compounds
  To change the name of perfluorinated compounds.

Surfactants
  To group the three different types of surfactants (anionic, cationic and non-ionic).

Footnote (2)
  To delete the footnote.

Footnote (4)
  To  change  it  to  accommodate  for  the  option  to  have  “one  or  a  combination  of
monitoring standards/methods”.
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Footnote (5)
  To clarify the text by describing the meaning of significant change.

New Footnote (6) and Footnote (7)
  To clarify the adaptation of monitoring frequencies in the case of indirect discharge.

1.4.2.2
Monitoring channelled emissions to air

Location
P. 726 – Section 5.1.2– BAT 8
in D1:
BAT 8. BAT is to monitor channelled emissions to air with at least the frequency given
below and in accordance with EN standards. If EN standards are not available, BAT is
to use ISO, national or other international standards that ensure the provision of data
of an equivalent scientific quality.

Minimum
Monitoring
Activities /
Substance/parameter
Standard(s)
monitoring
associated
processes
frequency
with
Singeing
Once  every
CO
EN 15058
Combustion
—
3 years
plants
Fabric
production
Once  every
Dust
EN 13284-1
Singeing
0
year (1) (2)
Thermal
treatment
Coating (3)
Flame lamination
Printing (3)
No
EN
Current
Singeing
Once  every
Formaldehyde
standard
0
text in
Thermal
year (1) (4)
available
D1:
treatment
after
finishing
and
after printing (3)
Coating (3)
Printing (3)
No
EN
Once  every
NH
Thermal
3
standard
0
year (1) (5)
available
treatment
after
finishing
and
after printing (3)
Singeing
Once  every
NO
Combustion
—
X
EN 14792

3 years
plants
Combustion
Once  every
SO
—
X (6)
EN 14791

plants
3 years
Coating
Lamination
Printing
Once  every
TVOC
EN 12619
0
Singeing
year (1) (7)
Thermal
treatment
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(1) The measurements are carried out at the highest expected emission state under normal
operating conditions.
(2) In the case of a dust mass flow of less than 50 g/h, the minimum monitoring frequency
may be reduced to once every 3 years.
(3) The monitoring only applies when the substance concerned is identified as relevant in
the waste gas stream based on the inventory of inputs and outputs mentioned in BAT
2.
(4) In the case of a formaldehyde mass flow of less than 2.5 g/h, the minimum monitoring
frequency may be reduced to once every 3 years.
(5) In the case of a NH3 mass flow of less than 50 g/h, the minimum monitoring frequency
may be reduced to once every 3 years.
(6) The monitoring does not apply if natural gas only is used as fuel.
(7)  In  the  case  of  a  TVOC  mass  flow  of  less  than  100 g/h,  the  minimum  monitoring
frequency may be reduced to once every 3 years.

BAT statement
  Amend the BAT statement as follows: “BAT is to monitor relevant channelled emissions
to  air  with  at  least…”,  as  only  pollutants  at  detectable  concentrations  should  be
monitored, not all the pollutants listed in the table (CZ_A 8, CZ_B 90).

Activities / processes
  Delete  for  several  parameters  “Singeing”  from  the  relevant  processes,  as  those
parameters are only relevant for combustion plants (EURATEX 112).

CO
  Delete  “Singeing”  from  the  relevant  processes,  as  CO  is  not  relevant  for  “Singeing”
(DE 342, EURATEX 133); CO is only relevant for combustion plants (EURATEX 148).

Dust
  Delete “Fabric production and Thermal treatment” from the relevant processes, as dust is
only relevant for “Singeing” (DE 170, EURATEX 149).
  Delete  “Fabric  production  and Thermal  treatment”  from  the  relevant  processes,  as  the
channelled emissions from these processes are not relevant (EURATEX 112).
  Delete  “Singeing”  and  replace  “Thermal  treatment”  with  “Finishing”.  Dust  is  only
relevant  for  combustion  plants  and  not  for  emissions  to  air  from  drying
(EURATEX 133).
Summary
  Add in relevant processes “Carpet cropping” or ensure that carpet cropping is included
of
within  the  definition  for  fabric  production.  Carpet  cropping  is  an  inherently  dusty
comment
process (UK 13).
s:
  Add a footnote to reduce the monitoring frequency from once every year to once every
three  years  (DE 354),  for  thermal  treatment,  when  there  is  an  alternative  control  of
emissions or stability of the process (EURATEX 40).

Formaldehyde
  Replace “Thermal treatment after finishing and after printing” with “Thermal treatment”,
as  formaldehyde  can  also  be  formed  under  incomplete  burning  conditions.  Expand  the
monitoring to directly heated thermal apparatus (DE 65).
  Delete  “Singeing”  from  the  relevant  processes  and  replace  “Thermal  treatment”  with
“Finishing”.  Formaldehyde  is  only  relevant  for  combustion  plants,  not  for  emissions
from drying (EURATEX 133).
  Replace “Thermal treatment after finishing and after printing”  with “Thermal treatment
after  finishing”,  as  the  source  of  formaldehyde  emissions  to  air  is  drying
(EURATEX 112).
  Add a definition for coating which covers carpet back-coating with latex, or clarify that
emissions  of  formaldehyde  from  carpet  back-coating  with  latex  are  covered  under
BAT 8. This parameter is a concern from a human health and environmental perspective
when there is a significant risk of it being emitted in significant quantities (UK 14).
  Reduce the monitoring frequency from once every year to once every three years, when
the emissions factor concept is applied every year for all recipes (DE 348).

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NH3
  Reduce the monitoring frequency from once every year to once every three years, when
the emissions factor concept is applied every year for all recipes (DE 348).

NOX
  Delete  “Singeing”  from  the  relevant  processes  as  NOx  is  not  relevant  for  “Singeing”
(DE 343).  NOx  is  only  relevant  for  combustion  plants  (EURATEX 112,
EURATEX 133).

TVOC
  Delete  “Singeing”  from  the  relevant  processes  and  replace  “Thermal  treatment”  with
“Finishing”.  TVOC  is  only  relevant  for  combustion  plants,  not  for  emissions  from
drying.  A  source  of  TVOC  emissions  to  air  is  the  use  of  chemical  products
(EURATEX 112, EURATEX 133).
  Add a definition for coating which covers carpet back-coating with latex, or clarify that
emissions of TVOC from carpet back-coating with latex are covered under BAT 8. This
parameter is a concern from a human health and environmental perspective when there is
a significant risk of it being emitted in significant quantities (UK 14).
  Reduce the monitoring frequency from once every year to once every three years, when
the emissions factor concept is applied every year for all recipes (DE 348).

Mass flow thresholds
  Clarify that mass flow threshold refers to the total emission mass flow of the installation,
not to a single stack (DE 70).

Footnote (1)
  Add  that  the  emission  factor  concept  described  in  Section 4.1.2.4  of  D1  is  used  to
determine  the  highest  expected  emission.  A  reliable  method  is  needed  to  predict  the
highest  expected  emission,  as  substances  change  quite  often  with  a  wide  range  of
different recipes (DE 125).

Footnote (3)
  Apply  Footnote  (3)  to  dust,  as  monitoring  should  be  carried  out  only  if  relevant
emissions are expected (DE 69).
  Apply Footnote (3) to formaldehyde for the relevant processes “Singeing”, according to
information included in Sections 2.6.1.1 and 3.5.4 of D1 (IT 11).
  Apply Footnote (3) to TVOC as monitoring for coating, lamination, printing and thermal
treatment is only relevant when solvents are used (EURATEX 41).

Footnote (6)
  Add  LPG,  as  the  sulphur  content  of  LPG  is  similar  to  natural  gas  (IT 10),  so  SOx
emissions are not relevant for liquid gas in heating units (DE 68).
  Apply Footnote (6) to dust for relevant processes “Thermal treatment”, as dust emissions
to air are not relevant when natural gas is used as fuel (EURATEX 40).

Footnote (7)
  Clarify  that  the  mass  flow  threshold  refers  to  the  total  emission  mass  flow  of  the
installation, not to a single stack (DE 67).
  Add  the  three  following  points,  to  clarify  that  the  footnote  does  not  contradict
requirements in Article 62, and special provisions reported in Chapter V of the IED:
- organic solvent consumption for coating exceeds 5 tonnes per year;
- organic solvent consumption of lamination exceeds 15 tonnes per year;
-  organic  solvent  consumption  for  rotary  screen  printing  exceeds  30  tonnes  per  year
(IT 12).

Additional footnotes
  Add  a  similar  footnote  to  Footnote  (1)  in  BAT 7,  to  monitor  pollutants  only  when
relevant  emissions  of  these  pollutants  are  expected.  For  example,  ammonia  is  not  a
general  pollutant  for  each  finishing  process  (DE 66,  DE 173,  EURATEX 151)  or
formaldehyde  emissions  are  only  relevant  when  formaldehyde  is  used  in  specific
processes or chemicals (DE 171, EURATEX 151).

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  Add a  new footnote  to allow for all parameters a  monitoring  frequency of once every
three years if the technique described in Section 4.1.2.4 of D1 (emission factor concept)
is applied or measurements with low and stable values are achieved (EURATEX 150).
  Add  a  new  footnote  to  increase  the  monitoring  frequency  for  larger  emitters  and  to
provide  more  proportionate  risk-based  monitoring  for  smaller  emitters,  as  monitoring
once every three years does not provide meaningful data to assess the potential impact of
the emissions to air (UK 15).

BAT statement
  Footnote (3) gives the flexibility to monitor only those parameters identified as relevant
in the inventory of inputs and outputs mentioned in BAT 2.
  For the  other cases  where  Footnote  (3) does not apply, the comment is  not clear as to
why the monitored parameters may not always be relevant for the processes concerned.

Activities / processes
  According  to  the  data  collection,  singeing  is  a  widespread  process  within  the  textile
industry.  Singeing  is  included  under  the  scope  of  the  BAT  conclusions  and  was  also
included  in  the  data  collection  (see  Section 8.5  of  the  KoM  report).  It  is  not  clear  for
which parameters singeing is not relevant or the reason why.

CO
  According  to  the  KoM  conclusions,  data  for  CO  emissions  from  singeing  should  be
collected. The technical justification for the changes proposed in the comment submitted
is not entirely clear. As stated in the scope of the BAT conclusions, when the generated
hot  gases  are  used  for  direct  contact  heating,  then  these  processes  are  included  in  the
scope of these BAT conclusions.
  A total of  3 out of  31  emission points to air  associated  with the  singeing process  (i.e.
ES058_{15},  ES058_{35}  and  SE120_{1})  have  reported  data  for  CO.  The  values
reported  for  the  3  emission  points  were:  ES058_{15}  reported  74.82  mg/Nm3  and  416
g/h,  ES058_{35}  reported  137.42  mg/Nm3  and  657  g/h,  and  SE120_{1}  reported  a
yearly average of 151,246 kg/year.
  Singeing is a burning process where  CO emissions can be  generated by an incomplete
combustion process when using fossil fuels. It is not clear why CO emissions to air are
not relevant for singeing.
EIPPCB

assessme
Dust
nt:
  The data collection shows that 13 emission points reported dust measurements for fabric
production in a  concentration  range  from 1 mg/Nm3  up to  23 mg/Nm3 and a  mass load
range from 8 g/h to 270 g/h. 20 emission points reported dust measurements for singeing
in a concentration range from 0.2 mg/Nm3 up to 20 mg/Nm3 and a mass load range from
0.8 g/h to 125 g/h. 67 emission points reported dust measurements for thermal treatment
in  a  concentration  range  from  0.02 mg/Nm3  up  to  112 mg/Nm3  and  a  mass  load  range
from 0.03 g/h to 461 g/h.
  Based on this data, it is not clear why singeing and thermal treatment are not relevant for
dust emissions.
  Dust is expected to be generated in combustion processes, either due to the type of fuel
or  the  textile  materials  which  are  in  contact  with  the  gaseous  products  of  combustion.
This can be clarified in the
  Regarding fabric production, it seems that the 13 EPs are connected to thermal treatment
and not to the fabric production itself (see also the assessment done for Table 5.6).
  Monitoring activities were harmonized with activities in table 5.6 (with BAT-AELs) and
are  proposed  for  emissions  from  singeing  and  from  thermal  treatments  as  steps
associated  with pre-treatment, dyeing, printing and  finishing. This has been clarified in
the wording of activities/processes column.
  The  proposed  monitoring  is  based  on  the  data  collection  and  no  data  were  collected
about emissions to air from carpet cropping.
  According  to  the  data  collection,  more  than  half  of  the  emission  points  that  have
measured  dust  emissions  from  thermal  treatment  have  done  so  with  a  monitoring
frequency  of  once  every  3  years.  This  could  be  reflected  by  applying  Footnote  (2)  to
thermal treatment.
  Regarding  the  use  of  an  emission  factor  to  reduce  the  monitoring  frequency,  no  data
have been reported on applying an emission factor for dust.
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Formaldehyde
  The processes it is proposed in BAT 8 to monitor are coating, flame lamination, printing,
singeing, and thermal processes after finishing or printing, all of them related  to the use
of  chemical  substances  and  high  temperatures.  According  to  the  data  collection,  the
concentration ranges for each of these processes are: coating and flame lamination from
0.3  to  20 mg/Nm3  and  a  mass  load  range  from  1.1 g/h  to  328 g/h,  printing  from
0.05 mg/Nm3  to  1.9 mg/Nm3  and  a  mass  load  range  from  0.3 g/h  to  36.5 g/h,  singeing
from  1.8 mg/Nm3  up  to  4.1 mg/Nm3  and  a  mass  load  range  from  5 g/h  to  20 g/h,  and
thermal treatment after finishing and after printing from 0.02 mg/Nm3 up to 20 mg/Nm3.
and a mass load range from 0.1 g/h to 328 g/h. Based on  these data, it is not clear  why
the processes proposed in BAT 8 are not relevant for emissions of formaldehyde to air.
These emissions could originate either from a combustion process where formaldehyde
is  formed  (e.g.  singeing  or  flame  lamination)  or  from  thermal  treatment  without  a
combustion process (e.g. drying) where formaldehyde or formaldehyde-prone substances
are  contained  in  process  chemicals  (see  BAT 46  and  BAT 47).  In  the  latter  situation,
Footnote  (3)  accounts  for  the  cases  where  process  chemicals  do  not  contain
formaldehyde or formaldehyde-prone substances.
  More  generally,  monitoring  activities  were  harmonized  with  activities  in  BAT  23  and
table  5.5.  BAT-AELs  are  proposed  for  emissions  from  processes  and  from  thermal
treatments  as  steps  associated  with  them.  This  has  been  clarified  in  the  wording  of
activities/processes column.
  The  proposed  monitoring  is  based  on  the  data  collection  and  no  data  were  collected
about emissions to air from carpet cropping.
  Emission  factors  can  be  one  tool  to  identify  that  formaldehyde  emissions  are  low.
Whether  or  not  the  emission  factor  concept  ensures  provision  of  data  of  an  equivalent
scientific  quality  than  a  monitoring  standard  method  is  in  the  remit  of  the  competent
authorities.  More  generally  speaking,  there  is  no  EN  standard  available  for
formaldehyde. As stated in the WBP and ROM reference documents, periodic sampling
of  formaldehyde  can  be  performed  using  two  different  methods  with  a  potential  for
difference in the measurement results. High volume isokinetic sampling in an impinging
solution  tends  to  give  higher  results  than  low  volume  non-isokinetic  sampling  on
adsorption tubes. According to the BAT statement, BAT is to use ISO, national or other
internal standards that ensure provision of data of an equivalent scientific quality.

NH3
  Regarding the comment related to the use of emission factors, see the assessment done
for formaldehyde.
  Add  the  new  monitoring  standard  for  channeled  emissions  of  NH3  to  air,  which  was
published on 30.04.2020: EN ISO 21877:2019.
  Monitoring activities were harmonized with activities in table 5.7 (with BAT-AELs) and
are  proposed  for  emissions  from  coating,  printing  and  finishing,  and  from    thermal
treatments  associated  with  them.  This  has  been  clarified  in  the  wording  of
activities/processes column.

NOX
  A total of  5 out of 31 emission points to air associated  with the  singeing process (i.e.
PT115_{10},  ES058_{35},  ES058_{15},  PT109_{3}  and  SE120_{1})  have  reported
data for NOx. The values reported for the 5 emission points were: PT115_{10} reported
8.2  mg/Nm3  and  28 g/h,  ES058_{35}  reported  18.8 mg/Nm3  and  90 g/h,  ES058_{15}
reported  18.8 mg/Nm3  and  105 g/h,  PT109_{3}  reported  27.1  mg/Nm3  and  26 g/h  and
SE120_{1} reported a yearly average of 135.53 kg/year.
  Singeing is a burning process where NOx emissions can be generated in the combustion
process when using fossil fuels. It is not clear why NOx emissions to air are not relevant
for singeing.

TVOC
  A total of 20 out of 31 emission points to air associated with the singeing process have
reported data for TVOC in a concentration range from 0.5 mg/Nm3 to 64 mg/Nm3, and a
mass  load  range  from  4 g/h  to  353 g/h.  According  to  the  data  collection,  it  is  not  clear
why TVOC emissions to air are not relevant for singeing
  Drying  is  included  in  the  definition  of  thermal  treatment.  According  to  the  data
collection,  162  emission  points  reported  data  for  TVOC  in  a  concentration  range  from
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0.2 mg/Nm3  to  223 mg/Nm3,  and  a  mass  load  range  from  0.04 g/h  to  3 380 g/h.
According to the data collection, it is not clear why TVOC emissions to air should only
be relevant for combustion plants.
  The  proposed  monitoring  is  based  on  the  data  collection  and  no  data  were  collected
about emissions to air from carpet cropping.
  Regarding the comment related to the use of emission factors, see the assessment done
for formaldehyde.
  Monitoring activities were harmonized with activities in table 5.5 (with BAT-AELs) and
are  proposed  for  emissions  from  coating,  dyeing,  finishing,  lamination,  printing  and
singeing,  and  from  thermal  treatments  as  steps  associated  with  them.  This  has  been
clarified in the wording of activities/processes column.
  TVOC as a parameter may include CMR substances other than formaldehyde (see Kick-
off  meeting  report),  therefore  it  is  proposed  to  monitor  such  substances  with  the  same
frequency as formaldehyde

Mass flow thresholds
  See the assessment for each parameter in Section 1.4.8 of this BP.

Footnote (1)
  How to determine the highest expected emission state under normal operating conditions
is  an  implementation  issue.  Indeed,  the  technique  described  in  Section 4.1.2.4  of  D1  is
an  option.  There  are,  however,  other  alternatives  such  as  techniques  described  in
Sections 4.1.1.2 and 4.1.2.3 of D1. Therefore, prioritising one technique over the others
does not seem necessary.
  Footnote  (1)  is  meant  to  ensure  that  the  emissions  are  monitored  even  at  the  highest
emission  state,  even  if  this  might  not  have  been  the  case  for  some  plants  in  the  data
collection. Such a footnote  was used in the latest adopted BAT conclusions (e.g. FDM,
STS) and a provision to apply the  measurements  to the extent possible could be added
also in these BAT conclusions.

Footnote (3)
  According  to  the  data  collected,  fabric  production,  singeing  and  thermal  treatment  are
processes  where  relevant  dust  emissions  have  been  reported  (see  assessment  above
related to dust). It is not clear in which circumstances dust may not be relevant.
  Formaldehyde  emissions  can  be  generated  in  a  combustion  process  (e.g.  singeing).
Clarification in Sections 2.6.1.1 and 3.5.4 of  D1 can be included.
  Footnote (7) gives the flexibility to monitor every 3 years, taking into account the use of
a  relevant  quantity  of  solvents.  Nevertheless,  it  could  be  possible  to  have  coating,
lamination,  printing  or  thermal  treatment  without  the  use  of  organic  substances.  This
could be reflected by applying Footnote (3) to the parameter TVOC.
  For  consistency  with  tables  5.5  and  5.7,  footnote  (3)  has  been  specified  for  Finishing
processes for formaldehyde and ammonia.

Footnote (6)
  The use of LPG is expected to be related to insignificant SOX emissions to air and this
can be further specified.
  Dust is not expected from combustion of natural gas; however, when using natural gas
the source of dust is not in the fuel but in the product itself. For example, emission points
PT109_{30},  PT109_{31},  FR135_{1},  PT109_{30},  PT114_{34}  and  PT109_{29}
reported a dust concentration range from 17.6 mg/Nm3 to 45.9 mg/Nm3 and a mass load
range  from  14.4 g/h  to  411 g/h,  for  processes  associated  with  thermal  treatment  and
using natural gas as fuel.

Footnote (7)
  Regarding  the  comment  about  the  mass  flow,  see  the  assessment  in  Section 1.3.1  and
Section 1.4.8 of this BP.
  The monitoring frequency proposed in Footnote (7) does not contradict the requirements
of Article 62 of the IED, i.e. measuring once every year fulfils the minimum monitoring
frequency of once every 3 years proposed in Footnote (7).
  On  the  other  hand,  according  to  the  provisions  of  Part 6  of  Annex  VII  to  the  IED,
channels  to  which  abatement  equipment  is  connected,  and  which  at  the  final  point  of
discharge  emit  more  than  an  average  of  10  kg/h  of  total  organic  carbon,  shall  be
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monitored  continuously.  According  to  the  data  collections,  no  plant  reported  a  TVOC
load  over  10 kg/h.  The  maximum  mass  load  reported  in  the  data  collection  for  TVOC
was 3.4 kg/h (IT059_{3}).

Additional footnotes
  Adding  a  general  footnote  on  all  parameters  that  the  monitoring  requirement  may  not
apply when the substance is not present in the waste would undermine the usefulness of
the  BAT  for  the  permit  writers.  Guidance  is  given  by  the  "Activities  /  processes"
column,  which  already  considers  the  expected  relevance  of  each  substance  for  each
process.
  All the parameters (except ammonia and formaldehyde) may be monitored once every 3
years,  if  the  emissions  are  below  a  specific  mass  flow  threshold,  which  could  be
estimated by using the emission factor concept.
  In  the  case  of  higher  emissions,  however,  it  is  not  clear  how  emission  factors  could
substitute actual measurements especially in the cases where EN standards are available.
In all recently published BAT conclusions (WI, FDM, etc.), TVOC is monitored as per
EN 12619.  Introducing  another  type  of  monitoring  would  not  be  consistent  with  the
other BAT conclusions and would lead to distortions in terms of a level playing field and
in terms of data comparability.
  The  principle  of  proportionality  is  encompassed  in  the  proposed  BAT 8  as,  for  some
parameters, the monitoring frequency is higher for larger emission sources and lower for
smaller emission sources.

BAT statement
  No change.

Activities / processes
  For  the  proposal  of  comments  regarding  activities/processes,  see  the  following
parameter-specific points.

CO
  No change.

Dust
  To delete fabric production in the column of Activities / processes.
  To add combustion in the column of Activities / processes
  To  clarify  in  the  column  of  Activities  /  processes  to  which  processes  the  thermal
treatments are associated.

Formaldehyde
  To add Finishing Activity/Process and clarity to which processes the thermal treatments
EIPPCB
are associated.
proposal:

NH3
  To add a new EN monitoring standard.
  To add Finishing Activity/Process and clarity to which processes the thermal treatments
are associated.

NOX
  No change.

SO2
  To  implement  a  minor  editorial  change  in  the  name  of  the  parameter,  as  combustion
plants are the main source of emissions to air.

TVOC
  To add Finishing Activity/Process and clarity wo which processes the thermal treatments
are associated.
  To add monitoring of CMR compounds.

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Mass flow thresholds
  To delete footnotes (4) and (5).

Footnote (1)
  To add ‘to the extent possible’.

Footnote (3)
  Add Footnote (3) for emissions to air for TVOC.
  To add footnote (3) to Finishing for formaldehyde and ammonia.

Footnote (6)
  To amend the footnote to include LPG as fuel with insignificant SO2 emissions to air.

Footnote (7)
  No change.

Additional footnotes
  Not to add additional footnotes.

1.4.3
Water use and waste water generation

1.4.3.1
Techniques for reducing water consumption and waste water
generation

Location in
P. 727 – Section 5.1.3 – BAT 9
D1:
BAT 9. In order to reduce water consumption and waste water generation, BAT is to
use all of the techniques given below.

Technique
Description
Applicability
Management techniques
A  water  management  plan  is  part  of
the EMS (see BAT 1) and includes:
  flow  diagrams  and  a  water  mass
balance  as  part  of  the  inventory
Current
of  inputs  and  outputs  mentioned  The  level  of  detail  of
text in D1:
in BAT 2;
the  water  management
Water
  establishment of water efficiency  plan    and  water  audits
a

management plan
objectives;
will
generally
be
and water audits
  implementation
of
water  related  to  the  nature,
optimisation
techniques
(e.g.  scale and complexity of
control
of
water
usage,  the plant
reuse/recycling,  detection  and
repair of leaks).
Water  audits  are  carried  out  at  least
annually  to  ensure  the  objectives  of
the water management plan are met.
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This includes:
  optimised
combination
of
processes
(e.g.
pretreatment
processes
are
combined,
bleaching  of  textile  materials  is
Production
avoided  before  dyeing  in  dark
b

Generally applicable
optimisation
shades);
  optimised  scheduling  of  batch
processes  (e.g.  dyeing  of  the
textile materials in dark shades is
carried  out  after  dyeing  in  light
shades  in  the  same  dyeing
equipment).
Design and operation techniques
Only applicable to new
plants  or  major  plant
upgrades.
Processes  that  do  not  use  water
Water-free
The  applicability  may
c

include  plasma,  laser  or  ozone
processes
be  restricted  by  the
treatments.
characteristics  of  the
textile  materials  and/or
product specifications
Batch  processes  are  carried  out  with
Optimisation  of  low-liquor-ratio
systems
(see
the  amount  of  Section 5.9.4).
d

process
liquor  Continuous  processes  are  carried  out
used
with low-volume application systems
(see Section 5.9.4).
This includes:
  water-free  cleaning  (e.g.  by
wiping  or  brushing  the  tanksʼ
Optimised
inner surfaces);
e

cleaning  of  the
  multiple  cleaning  steps  with  low
equipment
amounts  of  water;  the  water  of
the  last  cleaning  step  may  be
reused  to  clean  another  part  of
equipment.
This includes:
  use  of  auxiliary  tanks  for
Optimised  batch
temporary storage of:
processing,
o  spent  washing  or  rinsing  Generally applicable
f

washing
and
water;
rinsing  of  textile
o  fresh  or  spent  process
materials
liquor;
  multiple  drain  and  fill  steps  for
rinsing  and  washing  with  low
amounts of water.
This includes:
  timely process liquor preparation
based
on
online
pick-up
Optimised
measurements;
continuous
  automatic closure of the washing
processing,
water  inflow  when  the  washing
g

washing
and
machine stops;
rinsing  of  textile
  countercurrent
rinsing
and
materials
washing;
  intermediary
mechanical
dewatering  of  textile  materials
(see  BAT 12 b)  to  reduce  the
carry-over of process chemicals.
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Reuse and recycling techniques
Reuse  and/or  recycling  of  water
streams  (preceded  or  not  by  water
treatment),  e.g.  for  cleaning,  rinsing,
Water
reuse  cooling or in the processing of textile
h

and/or recycling
materials.  The  degree  of  water
reuse/recycling  is  limited  by  the
content  of  impurities  in  the  water
streams.
Generally applicable
Process  liquor,  including  the  process
liquor extracted from textile materials
by
mechanical
dewatering
(see
Reuse  of  process  BAT 12 b),  is  reused  after  analysis
i

liquor
and make-up if needed.
The degree of reuse of process liquor
is  limited  by
the  content  of
impurities.

Whole BAT
  For  increased  clarity  and  simplicity,  restructure  the  BAT  conclusion  into  two  BAT
conclusions: one on  water  management and the other on techniques  to reduce  water
consumption  and  pollutants  in  the  effluents.  Make  separate  techniques  of  the
techniques not grouped under the title “optimisation/optimised” not to lose relevance
(DE 418). See also the general comment (DE 396) on Chapter 5.

BAT statement
  Adjust the applicability or change the BAT statement to use "all" of the techniques
because some techniques are not applicable to all installations. For example, it is not
consistent to have both techniques c and d (DE 175, FR_B 6).

Management techniques
Technique a
  Specify whether the inventory of water inputs and outputs (BAT 2) is also covered by
the water management plan (BAT 9) (AT 40).
  Set BAT 9a as a "stand-alone" BAT conclusion because a water management plan is
a prerequisite for all techniques for the reduction of water consumption. It should be
implemented in all installations (DE 355). See the proposal, attached to the comment,
regarding prioritising this technique in a separate BAT conclusion (DE 418).
Summary
  Add  a  reference  to  BAT 5  in  technique  a  because  the  monitoring  results  (of  water
of
consumed  and  waste  water  generated)  shall  be  taken  into  account  when  optimising
comments:
water consumption and releases (FR_A 4).
  Decrease  the  frequency  of  water  audits  (e.g.  every  3  years),  provided  that  the
measures  to  be  implemented  between  audits  are  monitored  and  controlled  at  least
annually to ensure that the objectives are met (PT 12).
  Amend the applicability to also provide for a lower frequency of auditing for smaller
less complex sites (e.g. single process) to once every 4 years (UK 16).

Technique b
  Specify  distinct  combinations  of  pretreatment  processes  in  the  description,  e.g.
washing and bleaching or washing and desizing (DE 384). Explain in the description
what "optimised processes" are in Europe (DE 418).
  Specify that not all combinations of processes are possible, especially if the chemicals
used are incompatible. Also, scheduling may be limited by demands of processes, e.g.
if the process needs a subsequent step within a defined time (EURATEX 152).

Design and operation techniques
Technique c
  Delete the technique as laser, plasma and ozone techniques are emerging techniques
and  not  BAT.  There  is  no  information  available  about  the  implementation  of  the
laser/plasma  technique  in  the  questionnaire  of  Plant  DE042.  As  regards  the  ozone
technique, there is only one plant mentioned which is located in Tunisia (FR_B 5).
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  Change the applicability: laser and ozone treatment are only applicable for garment
treatment,  and  plasma  only  applicable  for  pretreatment,  e.g.  of  wool  (DE 345,
EURATEX 153).
  Specify  the  applicability  restrictions  for  different  treatments  in  line  with  the
descriptions of techniques in Chapter 4 or delete them. For example,  the description
for laser and plasma treatment in Section 4.7.1.1 of D1 does not justify any restriction
but  states  broad  applicability.  Similarly,  ozone  treatment  is  referred  to  in
Section 4.4.7.3  of  D1,  which  states  general  applicability  to  cellulose,  keratin  and
synthetic fibre (see also EEB 100 and EEB 105) (EEB 106, EEB 120).
Technique d
  Mention water-free processes under technique d, with the same structure as technique
e:  with  water-free  processes  as  a  first  bullet  and  the  second  bullet  the  remaining
current description because technique c and technique d cannot be applied at the same
time (FR_B 6).
  Split this technique into two separate techniques: i) Exhaust processing at low liquor
ratio  (LR  1:3–1:6)  for  discontinuous  pretreatment  and  exhaust  dyeing  of  all  fibres
except wool and silk; and ii) minimisation of the volume of padders and segregation
of  spent  padding  liquors  for  dyeing,  finishing,  laminating  or  coating  for  reuse  or
disposal and minimisation of the system volume from rotary printing and recycling of
residual printing pastes (DE 418).
  Change the applicability to “only applicable to new plants or major plant upgrades”
because the 'liquor ratio' depends on the type of dyeing machines; existing machinery
is not always equipped or adjustable for low-water processes and would therefore be
reduced  only  by  replacing  the  existing  machines  with  new  ones  (IT 13,
EURATEX 92).

Technique e
  Change the applicability to "only applicable to new plants or major plant upgrades"
because  water-free  cleaning  (wiping,  brushing  the  tanks'  inner  surface)  cannot  be
carried  out  in  a  safe  way  (safety  restrictions)  in  an  existing  tank  park  and  screen
cleaning system (EURATEX 92).
  Add  techniques  for  rotary  printing,  i.e.  mechanical  pre-cleaning  of  squeegees  and
rotary  screen  and  of  drums  containing  printing  pastes,  segregation  of  high
concentrated  spent  liquors  (padding  liquors)  before  washing  the  padder  (proposal
attached to the comment) (DE 418).

Technique f
  Change the applicability to “only applicable to new plants or major plant upgrades”
because the implementation of auxiliary tanks for temporary storage requires the new
piping to collect and transport the exhausted washing and rinsing waters (IT 41). The
piping/tanks may also be restricted by the space available (EURATEX 92).

Technique g
  Delete the bullet “intermediary mechanical dewatering of textile materials” because
its relevance for reducing water consumption (the purpose of BAT 9) is not clear. The
technique is more relevant to reduce energy consumption and is already listed in BAT
12 (FR_A 43).
  Add techniques: counter-current rinsing and washing and intermediary mechanical or
vacuum  dewatering  of  textile  materials  to  reduce  carry-over  of  process  chemicals
(proposal attached to the comment) (DE 418).
  Replace  “online  pick-up  measurements”  with  "the  pick-up  rates  pre-programmed
depending on the raw materials used" (FR_A 44).
  Change  the  introductory  sentence of the  description  to "This  may  include" because
these are only some examples of techniques (FR_B 1).
  Change the applicability to: “The applicability may be restricted by the characteristics
of  the  textile  materials  and/or  product  specifications”.  Technique  g  is  not  generally
applicable  because  the  listed  technologies  (online  pick-up,  automatic  closure,
countercurrent rinsing, etc.) are not used simultaneously in the same equipment. The
washing of textiles can be done at many stages during the production (EURATEX 7).

Reuse and recycling techniques
Technique h
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  Change the applicability to: “only applicable to new plants and major plant upgrades”
because  the  technique  requires  additional  piping,  which  can  only  be  done  during  a
major  upgrade.  Also,  reduction  of  water  consumption  by  recycling  of  process  water
can  include  high  costs,  energy,  storage  and  area/spatial  demands.  It  depends  on
ecological and economic efficiency (EURATEX 93, EURATEX 154).
  In the description, add “On site or off site centralised” to reuse and/or recycling of
water  streams.  Centralised  waste  water  management/recycling  systems,  adopted  on
site  or  off  site,  proved  to  be  highly  effective,  compared  to  (single)  internal  waste
water treatment system, allowing all companies, even the smallest ones, to contribute
in saving water resources (e.g. the Italian textile district of Prato in Tuscany) (IT 15).
  Add  specific  examples  of  reuse:  i)  reusing  the  washing  water  from  continuous
bleaching  of  cotton  woven  fabric  for  scouring  and  ii)  reusing  the  last  rinsing  water
from mercerisation for washing after bleaching (DE 418).

Technique i
  Change the applicability to: “Applicability may be restricted by impurities, colour and
storage  life”.  Colour  and  impurities  may  hamper  reuse.  Storage  life  may  also  be  a
constraint,  e.g.  it  is  limited  by  the  use  of  natural  thickeners  (CEFIC 28,
EURATEX 94).

Whole BAT
  The structure of this BAT conclusion is similar to some recent BAT conclusions (e.g.
STS, FMP).

BAT statement
  Several of the techniques listed are not generally applicable and consideration of the
applicability  restrictions  could  be  better  reflected  in  the  statement.  Furthermore,
technique  a  as  a  management  tool  would  have  merit  in  all  cases  where  water  is
consumed and/or waste water is generated.
  According to the data collection on BAT used at the plant level, ‘Water management’
and  ‘Optimisation  of  water  consumption’  are  used  by  86  and  69  out  of  106  plants,
respectively,  which  is  much  more  (4-5  times)  than  is  reported  for  other  techniques,
like  ‘Recycling/reuse’  16  or  ‘Reduction  of  water  consumption  for  cleaning’  (17
plants).  This  seems  to  support  the  argument  on  generic  use  of  techniques  a  and  b,
with the combination of other techniques.

Management techniques
Technique a
  The inventory of water inputs and outputs (BAT 2) could indeed be implemented as
an  integral  part  of  the  water  management  plan  (BAT 9a)  and/or  environmental
EIPPCB
management  system  (BAT 1).  This  is  indicated  by  the  cross  references  in  the
assessment:
description of the technique.
  Technique a could be a stand-alone conclusion. However, embedding it in the same
conclusion  might  strengthen  the  link  between  a  customised  water  management  plan
and audits and selection and implementation of the appropriate other techniques listed
in the same conclusion. Finally, this structure (i.e. management technique embedded
with other techniques) has already been used in BAT conclusions (e.g. WT, STS).
  The reference to BAT 5 is placed after Table 5.1 which is an integral part of BAT 9
and  therefore  does  not  seem  to  be  necessary  in  the  description  of  the  individual
techniques.  Should  Table  5.1  be  removed,  it  would  be  appropriate  to  include  the
reference in BAT 9a.
  The yearly frequency of water audits is harmonised with the one used in other BAT
conclusions  (e.g.  STS).  According  to  the  data  collection,  80 %  of  plants  discharge
more than 180 m3 of effluent per day (i.e.  at least 18 m3/t of textile treated), which
demonstrates the importance of water consumption for textile plants. Regular auditing
ensures  compliance  with  water  consumption  objectives;  therefore,  yearly  frequency
of  auditing  seems  reasonable.  On  the  other  hand,  the  level  of  detail  of  the  audit  is
already  included  in  the  applicability  clause  which  refers  to  the  nature,  scale  and
complexity of the plant.

Technique b
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  The examples of combinations of processes given in brackets are not exhaustive but
illustrative.  Since  BAT  35a  refers  to  more  specific  combinations  of  processes  for
cotton fibres, it seems more prudent to add these examples there.
  Production optimisation would be carried out on a case-by-case basis in each plant for
its specific products and process demands. It is considered that this is  a dynamic and
ongoing  decision-making  process,  reflecting  the  utilisation  of  the  plant’s  production
capacity. This technique lays out the principles of production optimisation and these
principles seem to be always applicable. However, parameters to be considered when
optimising the production could be added in the description in Chapter 4.
Technique b1
  To  better  reflect  the  technical  considerations  important  for  recovery/recycling
operations  a  new  technique  on  segregation  of  polluted/non-polluted  water  streams
could  be  added.  This  technique  is  considered  management  technique  and  could  be
used always. This could be reflected in BAT statement.

Design and operation techniques
Technique c
  Section  2.3.7.2.9  “Example  plants”  of  COM  Decision  2012/119/EU  (BREF
Guidance)  states:  "Reference(s)  to  a  plant(s)  where  the  technique  has  been
implemented  and  from  which  information  has  been  collected  and  used  to  draft  the
section of the BREF concerning that technique will be listed, including an indication
of  the  degree  to  which  the  technique  is  in  use  in  the  Union  or  worldwide.”  The
“Example  plants”  sections  of  ozone  (Section  4.4.7.3  of  D1  of  the  TXT  BREF)  and
laser/plasma  techniques  (Section  4.7.1.1  of  D1  of  the  TXT  BREF)  follow  this  rule.
Article 3(10) of the IED states that a technique is available if “developed on a scale
which  allows  implementation  in  the  relevant  industrial  sector,  under  economically
and technically viable conditions, taking into consideration the costs and advantages,
whether  or  not  the  techniques  are  used  or  produced  inside  the  Member  State  in
question, as long as they are reasonably accessible to the operator”. According to the
references  listed  in  Sections  4.4.7.3  and  4.7.1.1  of  D1  of  the  TXT  BREF,  the
techniques  mentioned  are commercially available and implemented on the industrial
scale; therefore, they are not considered emerging.
  The use of these techniques is versatile and under intensive development; therefore, it
seems  better  to  keep  the  description  very  generic  and  brief.  Moreover,  the  specific
uses in regard to the form of  the textile substrates do not seem to be  the (technical)
applicability restrictions but currently the most common modes of use. However, this
information could be added in the descriptions of techniques in Chapter 4.
  These technologies are related to the instalment of new treatment lines/machinery and
the corresponding utilities, which correspond to the definition of major plant upgrade.
Additionally,  the  currently  commercialised  techniques  cannot  universally  (for  all
types  of  fibre,  product,  quality)  replace  the  performance  of  conventional  wet
processing  treatments.  All  these  issues  are  reflected  in  the  proposed  applicability
restrictions and could be further detailed in Chapter 4.
  Laser  and  plasma  treatment  do  not  use  water,  while  ozone  treatment  is  typically
conducted in small amounts of water (as carrying medium).

Technique d
  Technique  c  and  technique  d  are  not  mutually  exclusive:  one  plant  could  have  a
water-free  production  line  and  a  second  line  based  on  wet  processes.  Merging  both
techniques  could  be  an  option  but  would  make  the  understanding  more  difficult
considering the applicability restrictions of technique c.
  It is not clear why these techniques would need to be separated. The proposed more
detailed  descriptions  are  already  included  in  BAT  conclusions  with  other
environmental  objectives  (e.g.  BAT 28  on  disposal  of  spent  process  liquors  or
BAT 44 for recovery of printing paste).
  Existing  machinery  can  hardly  be  upgraded  with  low-liquor-ratio  or  low-volume
application  systems  and  therefore  needs  to  be  replaced  (i.e.  major  plant  upgrade).
This could be reflected in the applicability.

Technique e
  The examples of water-free cleaning given in the description are illustrative and not
exhaustive.  It  is  not  clear  why  safety  restrictions  are  a  limitation  for  the  use  of  this
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technique.  The  applicability  of  water-free  cleaning  may  be  limited  by  accessibility.
This could be reflected in the applicability statement.
  The cross-reference to BAT 43 and example of mechanical cleaning in rotary printing
could  be  added  to  the  description.  Handling  of  highly  concentrated  spent  liquors  is
already addressed in BAT 43.

Technique f
  The  addition  of  auxiliary  tanks  and  piping  in  the  existing  plants  may  require
substantial  redesign  of  the  plant  layout  due  to  possible  space  restrictions,  which
would  be  undertaken  as  major  plant  upgrades.  This  could  be  reflected  in  the
applicability.

Technique g
  To avoid the contamination of the  following rinsing/washing bath, the intermediary
mechanical  dewatering  may  be  relevant  to  enable  water  reuse.  The  same  technique
can fulfil multiple environmental objectives.
  Vacuum  dewatering  is  one  of  the  mechanical  dewatering  techniques  used  in  the
textiles sector. This is specified in the description of BAT 12b cross-referenced in the
description.
  Use of pre-programmed pick-up for liquor preparation is static and not responsive or
customised to momentary changes. Modern machinery with automatic online pick-up
measurement feedback loops may reduce water consumption.
  The  list of measures given in the  technique’s description is  neither prescriptive  nor
exhaustive as mentioned in the General considerations.
  The  list  of  measures  given  in  the  technique’s  description  is  illustrative  and  is  not
intended  to  prioritise  the  measures  nor  to  stipulate  that  they  are  used  on  the  same
equipment simultaneously. In addition, it is not clear which textile materials or which
product specifications limit the applicability of these techniques.

Reuse and recycling techniques
Technique h
  The technological factors (like additional piping) and lack of space (e.g. for storage
tanks) could be the limiting factors in implementation of this technique. These factors
could  be  acknowledged  in  the  applicability  of  this  technique  or  related  techniques
(e.g.  see  applicability  of    new  technique  b1  on  segregation  of  water  streams,  or
technique f).
  The  textile  plants  may  be  located  within  bigger  industrial  sites  (with  many  plants)
where water management may be shared and carried out through a centralised utility,
affecting the plant’s reuse/recycling. The description could be amended to reflect this.
  The  examples  of  water  reuse  would  prolong  the  description  and  add  unnecessary
detail. They may be added to the technique description in Chapter 4.

Technique i
  The  issue  of  impurity  content  is  already  mentioned  in  the  description  as  it  is  an
important  part  of  the  use  of  this  technique.  The  perishability  of  the  process  liquor
could also be mentioned as an influencing factor (as in BAT 28c).

BAT statement
  To change the BAT statement to require the use of techniques (a), (b) and (b1) and an
appropriate  combination  of  the  rest  of  the  techniques  to  reflect  the  applicability
restrictions of several techniques.
Technique a
  The water audits are added to description of the technique to mirror the applicability.
  To add the integrated water management of plants on large sites to the description.
EIPPCB
Technique b1
proposal:
  Add  technique  on  the  segregation  of  the  water  streams  to  promote  their
reuse/recycling.
Technique c
  Modify the name and description to reflect that some processes use no and other little
water
Technique d
  To  change  the  applicability  of  the  technique  to  “only  applicable  to  new  plants  or
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major plant upgrades”.
Technique e
  To add examples for rotary printing (i.e. mechanical pre-cleaning of squeegees and
rotary  screen  and  of  drums  containing  printing  pastes)  and  a  cross  reference  to
BAT 43.
  To  add  the  accessibility  of  equipment  as  an  applicability  restriction  for  water-free
cleaning.
Technique f
  To  change  the  applicability  of  the  technique  to  reflect  lack  of  space  as  a  limiting
factor for existing plants.
Technique h
  To  reflect  in  the  description  that  textile  plants  on  the  same  site  can  have  common
water management (reuse/recycling/waste water treatment).
  To move high degree of reuse and/or recycling (>80%) to the description.
  To change the applicability to refer to the content of impurities and/or characteristics
of the water streams.
Technique i
  To add in the  description the perishability  as  an  influencing  factor for reuse  of the
process liquor.
BAT 35a
  In the description of technique a, add ‘washing’ to the treatments listed in brackets.

1.4.3.2
BAT-AEPLs for specific water consumption

Location in
P. 727 – Section 5.1.3 – BAT 9 – Table 5.1
D1:
Table 5.1: BAT-associated  environmental  performance  levels  (BAT-AEPLs)  for
specific water consumption
BAT-AEPL
Specific process(es)
(Yearly average)
(m3/t)
Batch
3–48 (2)
Bleaching (1)
Continuous
3–8
Scouring of cellulosic
Batch
2–43 (3)
materials (1)
Continuous
2–20
Desizing of cellulosic materials (1)
2–20
Mercerisation
2–13 (4)
Washing of synthetic material
5–20
Fabric
10–175 (5)
Batch dyeing
Yarn
3–140 (6)
Current
Loose fibre
13–62
text in D1:
Continuous dyeing
2–16
(1) The BAT-AEPL for the combined pre-treatment of cotton textiles by bleaching, scouring and
desizing  is 9–20 m3/t.  The  lower  end  of  the  range  is  typically  achieved  for  continuous
treatment.
(2)  The  lower  end  of  the  range  is  typically  achieved  with  a  high  level  of  water  recycling  (e.g.
above XX).
(3)  The  lower  end  of  the  range  is  typically  achieved  with  a  high  level  of  water  recycling  (e.g.
above XX).
(4)  The  lower  end  of  the  range  is  typically  achieved  with  a  high  level  of  water  recycling  (e.g.
above 85 %).
(5)  The  lower  end  of  the  range  is  typically  achieved  with  a  high  level  of  water  recycling  (e.g.
above 85 %).
(6)  The  lower  end  of  the  range  is  typically  achieved  with  a  high  level  of  water  recycling  (e.g.
above 95 %).

The associated monitoring is given in BAT 5.

Summary
Whole table
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of
  Develop a new table with different ranges for processes depending on parameters like
comments:
product  quality,  textile  substrate  etc.  in  a  sub-working  group  with  several  sector
experts.  The  process-specific  consumption  of  water  depends  mostly  on  the  product
type (e.g. some products need 3-4 process baths, others 15), material (cotton vs. PES),
fabric  weight  (40-3500  g/m²,  lightweight  curtains  or  nightdresses  vs.  heavy
nonwovens for sound protection or in buildings) or purpose (highly cleaned medical
or food contact textiles vs. textiles for dike stabilisation). The current presentation of
BAT-AEPLs  is  not  useful,  non-transparent  and  misleading.  If  appropriate  and
transparent  levels  for  water  consumption  could  not  be  achieved,  delete  Table  5.1
(DE  356).
  Replace  the  BAT-AEPLs  by  indicative  values  due  to  the  high  diversity  in  product
specification in the textile industry (DE 356, EURATEX 155).
  Set BAT-AEPLs in minimum recycling rates for specific processes because it would
be  more  relevant  to  better  environmental  performance  than  specific  water
consumption  ranges.  Based  on  the  analysis  of  the  recycling  levels/rates  and
identification  of  BAT  to  recycle  water  in  different  processes:  i)  narrow  down  the
BAT-AEPL ranges and ii) set BAT on recycling levels/rates (EEB 186).
  Increase the upper end of the BAT-AEPL range for specific water consumption levels
of  batch  dyeing,  i.e.  for  fabric  to  250  m3/t,  yarn  to  200 m3/t  and  loose  fibre  to
100 m3/t; due to the following factors: i) type of dye used (i.e. dyeing  with reactive
dyes) can affect the total required rinsing steps (e.g.  up to six); and similarly  ii) the
higher quality of textile products manufactured. See the Italian questionnaires IT067,
IT082, IT096, IT097 (IT 14).
  Narrow down the BAT-AEPL ranges as much as possible. For example, the ranges
for  batch  bleaching  (3-48 m3/t),  scouring  (2-43 m3/t)  and  dyeing  of  fabric  (10-
175 m3/t)  yarn  (3-140 m3/t)  are  very  large  and  do  not  seem  to  be  based  on
comparable  data  sets.  One  way  of  amending  this  would  be  to  remove  from  the
analysis  the  data  sets  for  specific  water  consumption  at  process  level  where  the
figures are the same as for total water consumption at the plant level (and more than
one process is in use on site). Examples are data sets from UK123 and UK124 where
it  was found that the data  for both  are  the  same because there is  no submetering on
site  and  the  operator  submitted  data  for  both  based  on  one  total  water  consumption
figure (UK 17).

Footnote (1)
  Change the upper limit for combined processes in Footnote (1) to 45 m3/t because it is
not logical compared to values of individual processes (EURATEX 95).

Whole table
  The BAT-AEPLs are derived from the process-level consumption data collected via
the  questionnaires.  Due  to  KoM  decisions,  these  data  were  considered  confidential,
meaning that only the EIPPCB could see the related contextual information (e.g. main
plant’s products, fibre treated, form of textile material, etc.).
  The  BAT-AEPL  proposals  in  D1  are  based  on  comparable  processes.  Further
detailing  and  classification  based  on  type  of  product  or  treated  textile  material  was
attempted.  However,  due  to  the  high  variability  in  processes,  textile  materials  and
forms, layouts/configurations of plants, affecting the  reliability of data reported, it is
deemed most practical to propose indicative values instead of BAT-AEPLs.
  The  proportions  of  recycled/reused  water  from  the  data  collection  exercise  were
EIPPCB
presented  in  figures  and  tables  together  with  water  consumption  levels  at  plant  and
assessment:
process level in Section 3.6.3 of D1. This information is considered when evaluating
data sets to be considered for setting the BAT-AEPLs; however, there is not enough
comparable  data,  due  to  various  different  local  and  technical  circumstances,  to
propose BAT-AEPL recycling levels at the plant or process level.
  Based  on  the  data  reported  in  the  questionnaires  for  Plants  IT067,  IT082,  IT096,
IT097, it was established that IT082 does batch dyeing of fabric, IT082 and IT097 do
batch dyeing of  yarn, and they all do batch dyeing of loose  wool fibre. The specific
water consumption  of these plants  is typically  within the proposed range, except for
one  of  them,  which  exceeds  the  proposed  upper  ends  of  the  corresponding  BAT-
AEPL  levels.  Therefore,  only  one  IT  plant  could  be  considered  for  increasing  the
proposed BAT-AEPL range for batch dyeing of loose fibres or yarns.
  Regarding the argument on dyeing with reactive dyes (requiring more rinsing steps),
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there are five plants, dyeing loose wool fibres or yarns with reactive dyes apart from
the one IT plant mentioned, reporting water consumption below the upper end of the
BAT-AEPL for batch dyeing of loose fibres or yarns. The information on the higher
quality of textile products manufactured was not collected through the questionnaires,
and, apart from the IT plants mentioned in the comments, it was not possible for the
EIPPCB  to  identify  other  such  plants.  Therefore,  the  data  and  information  available
do  not  support  increasing  the  upper  ends  of  BAT-AEPL  range  for  batch  dyeing  of
loose fibres or yarns.
  The data sets where the water consumption at the plant level exceeded the sum of the
consumption  reported  at  the  process  level  were  indeed  excluded  from  the  data  sets
used for setting the BAT-AEPL ranges.

Footnote (1)
  The  BAT-AEPL  range  for  combined  (one-step)  processes  is  derived  based  on  the
values  reported  in  the  questionnaires.  It  was  derived  as  the  sums  of  the  values
reported for the individual processes in those plants that indicated using the technique
of combined (one-step) pretreatment. The lower/upper ends of the water consumption
levels for individual continuous processes are based on all plants, those that use one-
step  pretreatment  and  those  that  do  not.  Therefore,  addition  of  the  values  of
lower/upper  ends  does  not  give  the  performances  achievable  with  the  technique
mentioned.
  To propose indicative values instead of BAT-AEPLs.
EIPPCB
  To  adapt  ranges  based  on  the  new  assessment  considering  TWG  comments,
proposal:
additional explanations and information provided.

1.4.4
Energy efficiency

Location in
P. 729 – Section 5.1.4
D1:
Current
Entire Section 5.1.4.
text in D1:
  Change the applicability in the BAT conclusions of this section to "only applicable to
Summary
new  plants  or  major  plant  upgrades  and  if  economically  feasible"  because  the
of
statements of BAT 10 to 12 say 'use all of the techniques' and not all techniques are
comments:
always and in every case applicable, or feasible (e.g. cogeneration is only useful when
there a constant and sufficient demand of heat) (CEFIC 30).
  The selection and implementation of some of the techniques in BAT 10, BAT 11 and
BAT 12 may be restricted by the substrate type, product quality requirements, type of
EIPPCB
processes  (e.g.  batch/continuous),  thermal  equipment  (dryers,  stenters),  off-gas
assessment:
treatment systems are their mutual compatibility. This could be reflected in the BAT
statements of the conclusions in this section.
EIPPCB
  To change the wording of the BAT statements in this section (5.1.4) to reflect that a
proposal:
combination of techniques is considered BAT.

1.4.4.1
Techniques for using energy efficiently

Location in
P. 729 – Section 5.1.4 – BAT 10
D1:
BAT 10. In order to use energy efficiently, BAT is to use all of the techniques given
below.
Current
text in D1:

Technique
Description
Applicability
Management techniques
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An  energy  efficiency  plan  is  part  of  the
EMS (see BAT 1) and includes:
  energy  flow  diagrams  as  part  of  the
inventory  of  inputs  and  outputs  (see  The  level  of  detail
BAT 2);
of
the
energy
Energy
  setting  objectives  in  terms  of  energy  efficiency
plan
efficiency  plan
will  generally  be
a.

efficiency
(e.g. MWh/t
of
textile
and
energy
materials processed);
related
to
the
audits
nature,  scale  and
  implementing  actions  to  achieve  these  complexity  of  the
objectives.
plant
  Energy  audits  are  carried  out  at  least
annually to ensure that the objectives of
energy efficiency plan are met.
Optimised  scheduling  of  fabric  batches  to
Production
Generally
b.

undergo  thermal  treatment  in  order  to
optimisation
applicable
minimise the idling time of the equipment.
Common techniques
This includes:
  burner maintenance and control;
  cogeneration;
  energy-efficient motors;
  energy-efficient lighting;
  optimising  steam  distribution  systems,
e.g. by using point-of-use boilers;
  regular  inspection  and  maintenance  of
the  steam  distribution  systems  to
prevent or reduce steam leaks;
Use  of  common

Generally
c.

  process control systems;
techniques

applicable
  reducing  heat  losses  by  insulating
equipment components and by covering
tanks  or  bowls  containing  warm
process liquor;
  optimising  the  temperature  of  the
rinsing water;
  avoiding  overheating  of  the  process
liquors;
  variable speed drives;
  optimising  air  conditioning  and
building heating.
Heat recovery techniques
Recycling
of  See  BAT 9 h.  This  avoids  the  need  for
d.

warm
cooling  heating cold water.
water
Reuse  of  warm  See  BAT 9 i.  This  avoids  the  need  for
e.

process liquor
heating cold process liquor.
Heat
recovery  Heat from waste water is recovered by heat
f.  fr om
waste  exchangers, e.g. to warm up process liquor.
water
Generally
Reuse
and/or  Warm  cooling  air  (e.g.  from  air-cooled  air  applicable
g.  r
ecycling
of  compressors) is reused and/or recycled (e.g.
warm air
for drying, after dedusting if needed).
Heat  from  waste  gases  (e.g.  from  thermal
Heat
recovery  treatment of textile materials, steam boilers)
h.  fr om
waste  is  recovered  by  heat  exchangers  and  used
gases
(e.g. to warm up process water or to preheat
combustion air).
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Heat
recovery  Heat,  e.g.  from  hot  condensate  and  boiler
i.

from steam use
blowdown, is recovered.

Management techniques
Technique a.
  Make  BAT  10a  a  "stand-alone-BAT".  An  energy  management  plan  is  indeed  a
prerequisite for all techniques for the reduction of energy consumption and should be
implemented in all installations (DE 357).
  Replace "energy audits" with "monitoring" because an energy efficiency plan is based
on an energy audit, which is performed periodically (e.g. every 4 years). The follow-
up of the energy plan is done via monitoring (EURATEX 96, CEFIC 29).
  Add the following footnote in the table: “EN ISO 50001:2018 is an example of a
management  system  compliant  with  BAT  10a”  for  easier  implementation
(ES 37).
  Include  the  possibility  to  carry  out  periodic  energy  audits  in  longer  periods  (for
instance every 6 years), as long as the measures are controlled annually (PT 13).
  Amend  the  applicability  to  provide  for  a  lesser  frequency  of  auditing  at  smaller
single-process sites and that demonstration of compliance with the technique may be
obtained  by  providing  the  audit  findings  and  summaries  from  other  similar  energy
efficiency schemes such as ISO 50001 (UK 18).

Common techniques
Technique c.
  Change the applicability for cogeneration which is applicable for all new plants and
for major refurbishments of existing plants where it may additionally be limited due
to the layout and available space (ES 18).
  Replace  "This  includes"  with  "This  includes  techniques  such  as"  because
cogeneration is not generally applicable (FR_A 45).
Summary

of
  Cogeneration  is  not  applicable  in  every  situation.  Therefore,  either  delete
cogeneration from the list of techniques, or move it to “Heat recovery techniques” to
comments:
be  applicable  in  combination  with  other  techniques  listed  there,  or  change  the
applicability  for  cogeneration  to  “Applicable  for  major  plant  upgrades”
(EURATEX 8).
  Replace the applicability with "only applicable to new plants or major plant upgrades
and  if  economically  feasible".  The  applicability  is  also  related  to  the  economic
feasibility and specific on-site situation (e.g. constant and sufficient heat demand for
cogeneration,  similarly  for  energy-efficient  motors,  energy-efficient  lighting  and
variable-speed drives) (EURATEX 97).

Heat recovery techniques
  The techniques listed cannot be used simultaneously in the same equipment, or they
require additional area (layout restrictions), or there is no process in which the warm
liquor  could  be  reused.  Therefore,  either  change  the  statement  to  “use  one  or  a
combination  of  the  listed  techniques”  (EURATEX 9)  or  change  the  applicability
restriction  for  heat  recovery  techniques  to  “Only  applicable  to  new  plants  or  major
plant upgrades” (IT 16, EURATEX 9).

Techniques f. and h.
  Change the applicability of the techniques to: "Only applicable to new plants or major
plant  upgrades"  because  the  implementation  of  these  techniques  is  closely  linked  to
the configuration of the installation (spatial layout) and sufficient high thermal energy
level suitable for recovery (operational conditions) (FR_A 46, IT 17, EURATEX 98,
EURATEX 99).  Economic  feasibility  should  also  be  reflected  in  applicability
(EURATEX 98, EURATEX 99).

BAT statement
  Several of the techniques listed are not generally applicable and consideration of the
applicability  restrictions  could  be  better  reflected  in  the  statement.  Furthermore,
EIPPCB
technique (a) as a management tool would have a merit in all cases where energy is
assessment:
consumed.

Management techniques
Technique a.
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  Technique  a.  is  a  management  tool  and  would  have  merit  in  all  processes  where
energy  is  consumed.  A  total  of  45  plants  from  the  data  collection  apply  an  energy-
saving plan (Section 4.1.4.1 of D1). According to the data collection on BAT used at
the plant level, ‘Management’ is used by 66 out of 106 plants,  which is  much  more
than  is  reported  for  other  techniques,  like  ‘Minimising  the  energy  consumption  of
stenters’  (30)  or  ‘Combined  Heat  and  Power’  (9  plants).  This  seems  to  support  the
argument on generic use of technique a. and only a combination of other techniques.
  Technique a. could be a stand-alone conclusion. However, embedding it in the same
conclusion  might  strengthen  the  link  betweena    customised  energy  efficiency  plan
and  audits  on  one  side,  and  selection  and  implementation  of  the  appropriate  other
techniques listed in the same conclusion on the other side. Finally, this structure (i.e.
management  technique  embedded  with  other  techniques)  has  already  been  used  in
BAT conclusions (e.g. STS).
  Energy  efficiency  plans  and  regular  energy  audits  are  important  tools  to  tap  the
energy-savings  potential  of  textile  installations.  Relevant  European  or  International
Standards,  such  as  EN  ISO  50001  (Energy  Management  Systems),  ISO  50002:2014
(Energy  audits  —  Requirements  with  guidance  for  use)  or  the  EN  16247  series
(Energy  Audits:  e.g.  Part  1  and  Part  3),  can  be  considered  when  establishing  an
energy  efficiency  plan  and  audits  as  part  of  an  environmental  management  system
(e.g. certified according to EMAS or ISO 14000). Apart from the note  in BAT 1, no
additional  footnotes  on  implementation  of  management  systems  are  deemed
necessary.
  Monitoring is usually considered as checking the change (e.g. measuring, calculating)
of a variable over time so that a certain set threshold value is not exceeded. Auditing
is  considered  a  more  comprehensive  and  structured  analysis  of  different  variables,
measures  and  processes  with  the  aim  of  acquiring  the  comprehensive  knowledge  of
different  aspects  of  a  plant’s  operation,  to  discover  the  improvement  potential  and
report on it.
  The energy audits in the scope of these BAT conclusions can be internal or external,
and it is left to the implementation stage to decide if the energy audits resulting from
other  regulatory  requirements  or  conducted  as  part  of  requirements  of  the  certified
energy  management  systems  are  considered  an  appropriate  demonstration  of
compliance. However, it could be reflected in the applicability that the level of detail
of  the  energy  audits  will  generally  be  related  to  the  nature,  scale  and  complexity  of
the plant.
  The consumption of energy in textile plants is substantial. The monitoring of energy
consumption is important information,  which is checked as part of the energy audit,
whose findings are used for verifying that the objectives of the energy efficiency plan
are  met.  The  yearly  frequency  of  energy  audits  is  harmonised  with  the  one  used  in
other  BAT  conclusions  (e.g.  FMP).  According  to  EMAS  Regulation  (EC)  No
1221/2009, Annex III, Part A, point 4, for complex activities (the IED activities could
be  considered  as  such)  the  audit  frequency  should  be  yearly.  Finally,  according  to
ISO  19011  or  the  EMAS  Regulation  (e.g.  Article  9),  internal  or  external  audits  are
possible. Since the level of detail of energy audits can be relatively simple in textile
plants,  it  is  not  clear  why  the  frequency  of  energy  audits  would  need  to  be  less
frequent.
  46  out  of  106  plants  reported  using  Energy  saving  plan  within  their  management
system,  14  reported  having  established  certified  energy  management  system
according to ISO 50001.

Technique b.
  Production  optimisation  is  management technique  that  could be  used generally  like
technique a. This could be reflected in BAT statement.

Common techniques
.Technique c.
  Implementation of cogeneration would require investment (e.g. CAPEX) in technical
infrastructure  (e.g.  adaptation  of  piping  and  installation  of  new  equipment  (e.g.  gas
turbine)) and substantial operating costs (e.g. OPEX). Both could be justified if there
is sufficient heat demand, making it economically feasible. This could be specified in
the applicability.
  Concerning  the  applicability  of  other  techniques  such  as  energy-efficient  motors,
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energy-efficient  lighting  or  variable-speed  drives,  these  pieces  of  equipment  can  be
installed  during  regular  maintenance  activities  when  the  existing  ones  need  to  be
replaced  and  it  is  not  clear  why  the  applicability  may  be  restricted  to  new  plants  or
major plant upgrades.
  The name of the technique could be made more technically relevant by referring to
energy-saving.

Technique c1.
  There  is a  merit to join bullets related to heating demand in a  dedicated technique.
Especially  insulation  of  equipment,  optimising  the  temperature  of  rinsing  water  and
avoiding overheating process liquors.

Heat recovery techniques
  The techniques listed in this conclusion cover the whole plant and not just one piece
of  equipment/process.  Therefore,  in  plants  with  multiple  processes  or  equipment,  it
would be possible to implement all of the techniques in the same plant. However, the
BAT  statement  gives  flexibility  to  implement  the  combination  of  techniques  which
would  make  it  possible  to  implement  some  of  them  despite  spatial  (layout)
restrictions or a lack of processes with heat demands.

Techniques f. and h.
  According to the data collection, heat recovery from waste water and waste gases is
relatively widely used in the sector (see Section 3.6.3 of D1, Figures 3.79 and 3.71).
Specifically,  40  plants  reported  recovering  heat  from  waste  water,  27  from  process
waters,  and  25  from  waste  gases.  This  indicates  that  these  techniques  are  widely
implemented in the sector. The layout of the plant and the heat demand affect the heat
recovery, but many of the heat recovery loops could be implemented without a major
plant  upgrade.  Moreover,  the  BAT  statement  gives  flexibility  to  implement  the
combination of techniques, which would make it possible to implement some of them
despite spatial (layout) restrictions and/or the lack of processes with heat demands.

Technique g.
  Technique  g.  would  be  better  placed  in  BAT 11  which  addresses  specific  issues
related to the energy efficiency of air compressors.

Technique b1.
  For the assessment, see Section 1.4.4.2.
BAT statement
  To change the wording “to use all of the techniques” in the BAT statement to require
the  use  of  techniques  a.  and  b.  and  appropriate  combination  of  the  rest  of  the
techniques to reflect the applicability restrictions of several techniques.
Technique a.
  To add the applicability restrictions regarding the level of detail of energy audits.
Technique b1.
  To be moved from BAT 12 a.
EIPPCB
Technique c.
proposal:
  To reflect in the applicability that cogeneration in existing plants may be restricted by
a suitable heat demand.
  To amend the name of technique to reflect the energy saving objective.
Technique c1.
  To make new technique on heating demand from some of the examples in technique
c.
Technique g.
  To delete in the technique from this BAT conclusion and to move it to BAT 11d.

1.4.4.2
Techniques for increasing energy efficiency of thermal treatment

Location in
P. 731 – Section 5.1.4 – BAT 12
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D1:
BAT 12. In order to increase the energy efficiency of thermal treatment, BAT is to
use all of the techniques given below.

Technique
Description
Applicability
Techniques for reducing the use of heating
Wet-on-wet
Dyeing  or  finishing  liquors  are  applied
dyeing
or
a.

directly to the wet fabric, thus avoiding an
finishing
of  intermediate drying step.
fabric
The  water  content  of  textile  materials  is
Mechanical
Generally
reduced  by  mechanical  techniques  (e.g.
b.  d  ewatering
of
applicable
centrifugal  extraction,  squeezing  and/or
textile materials
vacuum extraction).
Avoiding
The  textile  materials  are  not  dried  below
c.  o  verdrying
of  their natural moisture level.
textile materials
Design and operation techniques
This includes:
  the  number  of  air  injection  nozzles  is
adapted to the width of the fabric;
Only  applicable  to
Optimising  air
  the  distance  between  the  nozzles  and  new  plants  or
d.

circulation
in
the fabric is as short as possible;
major
plant
stenters
  the  pressure  drop  caused  by  the  upgrades
Current
stentersʼ  internal  components  is  as
text in D1:
small as possible.
The  following  drying  parameters  are
monitored and controlled (see BAT 3):
  humidity  content  and  temperature  of
the inlet air;
  temperature of textile materials and air
Advanced
within the dryer;
process

Generally
e.

monitoring  and
  humidity  content  and  temperature  of
applicable
control
of
the  exhaust  air;  drying  efficiency  is
drying
optimised  by  a  high  humidity  content
(e.g. above 0.1 kg water/kg dry air);
  residual moisture content of the fabric.
The exhaust airflow is adjusted to optimise
drying  efficiency  and  is  reduced  during
idling time of drying equipment.
Only  applicable  to
Microwave
or  Drying  of  textile  materials  with  high-
new
plants
or
f.  r
adio-frequency
efficiency  microwave  or  radio  frequency  major
plant
dryers
dryers.
upgrades
Heat recovery techniques
Heat
recovery
Generally
g.  fr om
waste  See BAT 10 h.
applicable
gases

Whole BAT
  Clarify the scope of the BAT and possibly split the techniques between several types
of  thermal  treatments.  For  example,  it  is  not  clear  why  the  techniques  listed  are
specific only to the thermal treatment. Some techniques could be implemented even if
Summary
there  is  no  thermal  treatment.  It  is  also  not  clear  what  thermal  treatments  it  covers
of
(FR_B 3).
comments:

BAT statement
  Change the statement to: “BAT is to use one or more of the techniques given below”,
because all of the listed techniques cannot be used simultaneously (EURATEX 10).

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Techniques for reducing the use of heating
Technique a.
  Change the applicability to: "Not applicable to continuous processes or when the pre-
treated fabric need to be stored before being dyed or finished because of operational
constraints." Production scheduling (especially in commission firms) and operational
restrictions may demand different sequencing and hence intermediate drying to avoid
moulds.  Moreover,  continuous  dyeing/finishing  on  wet  fabric  may  require  higher
chemicals consumption (dosing) to ensure a homogeneous treatment and the required
product specifications (e.g. up to 3 times higher use of optical brighteners, softeners
or water-repellent resins) (CZ_B 5, CZ_A 9, CZ_A 12, FR_A 47, EURATEX 10).
  Add  that  the  applicability  may  be  restricted  by  potential  reactions  between  unfixed
chemicals on the wet fabric (EURATEX 113).

Technique b.
  Add  that  the  applicability  of  mechanical  drying  may  be  restricted  by  the  textile
characteristics (i.e. it can withstand it) (EURATEX 113).
  Modify the applicability to: “The applicability may be restricted by the characteristics
of the textile materials and/or product specifications.” (IT 19).

Design and operation techniques
Technique e.
  Not  all  parameters  need  to  be  monitored,  so  add  “such  as”  after  “(See  BAT  3)”
(FR_A 48).
  The  residual  moisture  of  the  fabric  is  more  often  monitored  compared  to  the  other
parameters  listed.  Moreover,  a  high  humidity  content  in  the  exhaust  air  can  lead  to
deposits  within  the  stack  and  the  risk  of  fire  and  in  addition  it  may  result  in
condensation that causes spots on the fabric (FR_A 48).
  Change technique e. as follows: delete the first bullet point and change the third bullet
point  to  "humidity  content  and  temperature  of  the  exhaust  air;  drying  efficiency  is
optimised". Also, change the applicability to “only applicable to new plants or major
plant upgrades” (EURATEX 10).
  Add that the applicability of input temperature and humidity control may be restricted
by  other  parameters.  For  example,  high  exit  air  humidity  is  only  possible  if  other
parameters allow (EURATEX 113).

Technique f.
  Modify the applicability as it may be restricted by product specifications, e.g. textiles
containing  metallic  fibres  (especially  in  ATEX/explosive  areas)  (ES 16,
EURATEX 12)  or  change  it  to  “only  applicable  to  new  plants  or  major  upgrades”
(EURATEX 12).
  Delete  the  technique  as  it  is  an  emerging  technique  and  not  BAT,  or  change  the
applicability to "not applicable to fabric containing metallic fibres." Also, there are no
example plants which apply this technique mentioned in the BREF and no data in the
questionnaires (FR_A 49).

Heat recovery techniques
Technique g.
  Change the applicability to reflect that the technique  is generally applicable to new
plants  and  major  upgrades  of  plants  because,  depending  on  the  configuration  of
existing plants, it may not be easy to install, and that it depends on heat needs and the
calorific value of the off-gases (FR_A 62).

Whole BAT
  The  scope  of  the  technique  is  energy  efficiency  of  thermal  treatment.  Splitting  the
techniques  according  to  the  type  of  thermal  treatment  could  prove  repetitive  and
complex. The generic table seems a very clear and understandable way of presenting
EIPPCB
the techniques.
assessment:
  A definition of thermal treatment is given in the Definitions.
  Technique  b.  “Mechanical  dewatering  of  textile  materials”  is  not  specific  only  to
energy efficiency of thermal treatment but also to other environmental objectives, i.e.
water consumption/waste  water generation (see BAT 9g and BAT 9i). It is not clear
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how other techniques in this conclusion could be implemented if no thermal treatment
was carried out in the plant.

BAT statement
  The techniques of this BAT conclusion cover the whole plant and not just one piece
of  equipment/process.  Therefore,  in  plants  with  multiple  processes  or  pieces  of
equipment, it would be possible to implement all of the techniques in the same plant.
However,  in  line  with  the  general  approach  adopted  for  BAT  conclusions  in  this
section  (see  Section  1.4.4 of  this  document),  the  BAT  statement  could  reflect  that  a
combination of techniques could be implemented to achieve its objective.

Techniques for reducing the use of heating
Technique a.
  Technique a. does not increase the energy efficiency of thermal treatment, but reduces
the need for a thermal treatment step, and thereby increases the energy efficiency of
the plant. Therefore, it would be more appropriate to include it in BAT 10 on general
(plant-level) energy efficiency techniques.
  It is not clear why wet-on-wet dyeing is not applicable to continuous processes since
it can be carried out on continuous ranges with the padding machines (e.g. Foulard) in
various combinations (e.g. pad-pad-steam), but also with spray and foam application.
It is suitable for fabrics which have the ability to retain substantial amounts of liquids
(e.g. terry cloth, corduroy), e.g. with density typically above 140 g/m2.
  Production  scheduling  in  relation  to  energy  efficiency  is  addressed  by  technique
BAT 10b.  It  does  not  seem  to  limit  or  contradict  the  implementation  of  wet-on-wet
dyeing or finishing.
  The note on the potential higher finishing agent consumption (up to three times more)
to  ensure  product  quality  could  be  added  in  Chapter  4,  but  there  was  no  specific
information on which finishing processes (agents) this refers to.
  No specific information on potential reactions between unfixed chemicals and textiles
was provided (e.g. for which type of dyes or which fibre combinations).

Technique b.
  No information on potential restrictions related to mechanical drying and the textile
properties  (e.g.  withstanding  mechanical  pressure  from  harming  the  substrate)  was
provided.

Design and operation techniques
Technique e.
  The  drying  parameters  described  are  indicative.  This  could  be  reflected  in  the
description.
  It is not clear why this technique is only applicable to new plants and major upgrades.
  It  is  not  clear  which  other  parameters  would  limit  the  high  humidity  content  of
exhaust air exiting the dryer.

Technique f.
  Microwave or radio-frequency drying of textile materials with metallic fibres or other
metallic  parts  (e.g.  buttons)  may  not  be  possible.  This  could  be  mentioned  as  a
technical applicability restriction of this technique.
  High-frequency  drying  has  been  reported  to  be  used  by  Plants  BE010,  IT082  and
PT105 and is largely described in the existing TXT BREF as an applied process. See
also the site visit reports dated 05/03/2019 and 11/04/2019.

Heat recovery techniques
Technique g.
  It  is  not  clear  how  installation  difficulties  or  the  calorific  value  of  the  waste  gases
would  change  with  a  major  plant  upgrade.  It  is  hard  to  imagine  a  lack  of  heat
demands  in  the  textile  sector,  where  a  lot  of  processes  require  heat.  Moreover,  the
BAT  statement  gives  flexibility  to  use  a  combination  of  techniques  to  achieve  the
objective  of  heat  efficiency  in  thermal  treatment,  so  indeed  satisfactory  energy
efficiency may be achieved without implementing this technique.

EIPPCB
BAT statement
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proposal:
  To rephrase the statement to “use a combination of the techniques”.
Technique a.
  To move the technique to BAT 10 on energy efficiency.
Technique e.
  To modify the introductory sentence of the description to reflect the indicative nature
of the parameters listed.
Technique f.
  To add the applicability restriction for textile materials containing metallic parts.

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1.4.4.3
BAT-AEPLs for specific energy consumption

Location in
P. 727 – Section 5.1.3 – BAT 12 – Table 5.2
D1:
Table 5.2: BAT-associated  environmental  performance  levels  (BAT-AEPLs)  for
specific energy consumption
Current
BAT-AEPL
text in D1:
Process
Unit
(Yearly average)
Thermal treatment
MWh/t
0.5–4.4
The associated monitoring is given in BAT 5.
Whole table
  As for Table 5.1, develop a new table with different ranges for processes depending
on parameters like product quality, textile substrate etc. in a sub-working group with
several sector experts. The process-specific consumption of water depends mostly on
the  product  type  (e.g.  some  products  need  3-4  process  baths,  others  15),  material
(cotton vs. PES), fabric weight (40-3500 g/m², lightweight curtains or nightdresses vs.
Summary
heavy  nonwovens  for  sound  protection  or  in  buildings)  or  purpose  (highly  cleaned
of
medical or food contact textiles vs. textiles for dike stabilisation). The proposed range
comments:
is not useful to be used as a BAT-AEPL (DE 262).
  Remove  from  the  analysis the  data  sets for  specific energy consumption  at  process
level where the figures are the same as for total energy consumption at the plant level
(and  more  than  one  process  is  in  use  on  site).  Examples  are  data  sets  from  UK124
where due to lack of sub-metering the same figure was reported for both (UK 19).

Whole table
  Because it was not clear whether the values reported for the wet processes include the
energy  needed  for  drying  or  only  the  energy  needed  for  heating  liquors  (water),  the
specific energy consumption was proposed for thermal treatments only. Limiting  the
water  consumption  of  wet  processes  through  indicative  values  for  specific  water
consumption would indirectly limit their energy consumption.
EIPPCB
  Due  to  the  high  variability  in  processes,  textile  materials  and  forms,
assessment:
layouts/configurations  of  plants,  affecting  the  reliability  of  data  reported,  and  the
limited extent of TWG participation in the data analysis (e.g. due to the CBI nature of
data),  it  is  deemed  more  practical  to  propose  indicative  values  instead  of  BAT-
AEPLs.
  The data sets where the energy consumption at the plant level exceeded the sum of
the consumption reported at the process level were indeed excluded from the data sets
used for setting the BAT-AEPL ranges
EIPPCB
  To propose indicative values instead of BAT-AEPLs.
proposal:

1.4.5
Chemicals

1.4.5.1
Techniques for improving the overall environmental performance

Location in
P. 732 – Section 5.1.5 – BAT 13
D1:
BAT  13.  In  order  to  improve  the  overall  environmental  performance,  BAT  is  to
elaborate and implement a chemicals management system (CMS) as part of the EMS
(see BAT 1) that incorporates all of the following features:
I.  process  chemicals  procurement  policy  to  select  process  chemicals  and  their  suppliers
Current
with the aim to minimise the use of hazardous chemicals such as substances of very high
text in D1:
concern and to avoid the procurement of excess amount of process chemicals. In order to
reduce  emissions  to  air,  the  selection  of  process  chemicals  may  be  based  on  emission
factors (see Section 5.9.1);
II.  anticipatory  monitoring  of  regulatory  changes  related  to  hazardous  chemicals  and
safeguarding compliance with applicable legal requirements;
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chemicals inventory (see BAT 14);
III.  identification  of  the  process  chemicals  pathways  through  the  plant  (from  procured
process chemicals to products, waste and emissions);
IV. assessment of the risks associated to the chemicals, based on the chemicals’ hazards,
concentrations  and  amounts.  This  may  include  an  estimation  of  their  emissions  to  the
environment;
V.  regular  (e.g.  annual)  check  aiming  at  identifying  potentially  new  available  and  safer
alternatives to the use of hazardous chemicals (e.g. changes of process(es) or use of other
chemicals with no or lower environmental impacts such as enzymes);
VI. goals and action plans to avoid or reduce the use of hazardous chemicals;
VII.  development  and  implementation  of  procedures  for  the  handling,  storage,  use  and
return of process chemicals (see BAT 20).

The  criteria  for  selecting  process  chemicals  and  their  suppliers  may  be  based  on
certification schemes or standards. In that case, the compliance of the process chemicals
and their suppliers with these schemes or standards is regularly verified.

Applicability
The  level  of  detail  of  the  CMS  will  generally  be  related  to  the  nature,  scale  and
complexity of the plant.

Point I
  Replace  “the  use  of  hazardous  chemicals”  with  “the  emissions  of  hazardous
chemicals”  as  the  amount  of  hazardous  chemicals  used  depends  on  the  plant
throughput (CEFIC 5).
  Clarify what is meant by "substances of very high concern" and if relevant make a
reference to the candidate list of REACH (FR_A 6).
  Replace  "such  as  substances  of  very  high  concern"  with  "in  the  meaning  of  IED
Article  3(18)”  as  SVHC  are  only  a  small  fraction  of  the  hazardous  substances
(EEB 86).
  Delete the reference to “substances of very high concern” as it is already regulated by
REACH (CEFIC 6).

Point II
  Put the chemical inventory in a separate bullet point, maybe the first one as it is the
starting point for the management of chemicals (FR_A 10).

Point IV
  Merge  Points  IV  and  VII  as  the  risks  associated  with  chemicals  are  the  basis  to
identify risk management measures (FR_A 8).
Summary
  Replace  the  word  “risk”  with  “hazard  x  exposure”  to  ensure  coherence  with  the
of
REACH  and  CLP  Regulations.  How  to  perform  a  risk  assessment  for  chemicals  is
comments:
described in the ECHA Guidance on Information Requirements and Chemical Safety
Assessment (CEFIC 7).

Point V
  Specify  that  “hazardous  chemicals”  are  “chemicals  which  are  restricted  by  EU  or
international  regulations  (e.g.  CMR  substances  in  CLP-Regulation,  SVHC  in  article
57a-f  of  the  REACH  Regulation,  POPs  listed  in  the  Stockholm  Convention)”
(AT 43).
  Remove the  mention  of  “safer chemicals” and refer instead to alternative processes
and  chemicals  with  no  or  lower  environmental  impacts,  which  is  the  final  aim
(CEFIC 8).
  Delete the reference to enzymes as the impact on the environment is also a question
of  emission,  exposure  and  concentration  and  not  only  a  property  of  a  substance
(CEFIC 9).

Point VI
  Delete Point VI as it is redundant with Point I (FR_A 7).
  Replace “avoid or reduce the use of hazardous chemicals” with “avoid or reduce the
emissions of hazardous chemicals”, which is the real target (CEFIC 10).

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Point VII
  Add procedures to collect spent bath and pastes for reuse or disposal as waste, as they
contain high concentrations of chemicals (SE 13).
  Clarify  the  return  of  chemicals  as  follows:  “return  of  unused  process  chemicals  to
suppliers” (FR_A 9).

Criteria for selecting process chemicals and their suppliers
  Add  examples  of  certification  schemes  or  standards  (e.g.  ECO  PASSPORT  by
OEKO-TEX®,  STeP  by  OEKO-TEX®,  DETOX  TO  ZERO  by  OEKO-TEX®)
(ES 14, EURATEX 101).
  Add that the selection of chemicals may be done via “positive” lists of chemicals (i.e.
list  of  preferred  chemicals  that  are  assessed/screened  and  validated  by  neutral  third
parties for their toxicological and ecological profile) (DE 215).

General comment
  Restructure the BAT according to the following order of priority:
o  management  techniques  to  avoid  or  (if  not  possible)  minimise  the  use  of
hazardous chemicals (like SVHC);
o  techniques for selection of chemicals with the aim to reduce emissions (including
anticipatory survey of alternatives for used substances);
o  identification of emission pathways of substances used;
o  techniques for handling, storage.
The proposed wording is the following: (DE 358)

BAT 13. In order to improve the overall environmental performance, BAT is to elaborate
and  implement  a  chemicals  management  system  (CMS)  that  incorporates  the  following
features:
I.
process  chemicals  procurement  policy  to  select  process  chemicals  and  their
suppliers  with  the  aim  to  minimise  the  use  of  hazardous  chemicals  such  as
substances of very high concern as described in Article 57 REACH as substances
with  CMR-properties  (Category  1A  and  1B),  PBT  or  vPvB  substances,  or
substances  with  an  equivalent  level  of  concern,  such  as  endocrine  disrupting
chemicals;
II.
goals  and  action  plans  to  avoid  or  reduce  the  use  of  hazardous  chemicals  and
substances  that  may  pass  existing  barriers  in  concentrations  that  may  raise
concern;
III.
Selection of recipes for textile finishing based on the application of the emission
factor  concept  (see  Section  5.9.1)  as  a  tool  that  allows  for  assessing  and
predicting  air  emission  released  from  chemical  auxiliaries,  e.g.  during  thermal
treatment.
IV.
Selection  of  process  chemicals  considering  their  eliminability  to  minimize  the
release  into  water  as  well  as  their  effect  to  the  aquatic  compartment  (eco-
toxicity).
V.
anticipatory  monitoring  of  regulatory  changes  related  to  hazardous  chemicals
and safeguarding compliance with applicable legal requirements;
VI.
regular  survey  whether  new  and  safer  alternatives  to  the  use  of  hazardous
chemicals are available
VII.
identification  of  the  process  chemicals  pathways  through  the  plant  (from
procured process chemicals to products, waste and emissions)
VIII.
assessment  of  the  risks  associated  to  the  chemicals  based  on  the  chemicals’
hazards, concentrations and amounts. This should include an estimation of their
emissions to the environment;
IX.
development  and  implementation  of  procedures  for  the  handling,  storage,  use
and return of process chemicals.

Point I
  Point  I  is  about  the  procurement  policy,  which  can  contribute  to  the  reduction  of
emissions  of  hazardous  chemicals  by  minimising  the  procurement  and  therefore  the
EIPPCB
use  of  hazardous  chemicals.  This  does  not  contradict  the  fact  that  the  amount  of
assessment:
chemicals used also depends on the plant throughput.
  The criteria for determining BAT do not concern only emissions to the environment.
The reduced use of hazardous chemicals also addresses the following aspects, which
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are listed in Annex III to the IED as criteria for determining BAT:
o  the use of less hazardous substances;
o  the consumption of raw materials used in the process.
  It  would  therefore  be  limiting  to  mention  only  the  reduction  of  emissions  as  the
objective of point I.
  The  term  “hazardous  chemicals”  may  be  unnecessary  as  it  is  the  term  “hazardous
substances” which is defined in Article 3(18) of the IED (which refers to Article 3 of
the CLP Regulation) and mentioned in Annex III to the IED.
  The term “substances of very high concern” would need a definition in Definitions.

Point II
  The chemical inventory not being in a separate point is due to a formatting issue.
  It  is  not  necessarily  the  first  point  of  the  CMS  as  a  management  system  would
normally start by setting an overall objective and an associated action plan.
  BAT  14  is  dedicated  to  the  chemical  inventory,  but  its  role  in  the  CMS  could  be
specified.

Point IV
  Procedures mentioned in point VII of the CMS consider the risks associated with the
chemicals  and  identified  in  point  IV  but  not  exclusively.  It  can  also  consider  for
example  the  shelf  life  of  the  chemicals  or  the  return  of  unused  chemicals.  It  seems
therefore clearer to have two separate points. This being said, the connection between
both  points  could  be  clearer  by  having  the  point  about  risk  assessment  immediately
before the point about the development of procedures.
  Article 14 of the REACH Regulation lays out the provisions for the realisation of the
chemical safety assessment. This safety assessment is based on the assessment of the
hazards  induced  by  the  substance  or  mixture  concerned  and,  depending  on  the
outcomes of this assessment, is complemented by an exposure assessment and a risk
characterisation8.  The  risk  characterisation  in  turn  allows  the  identification  of  risk
reduction  measures.  A  better  alignment  of  the  wording  of  point  IV  with  the
terminology used in the REACH regulation would improve clarity.

Point V
  The  term  “hazardous  chemicals”  is  not  defined  in  the  IED  or  in  other  relevant
regulations (REACH or CLP). On the other hand, the term “hazardous substances” is
defined in the IED and the use of the same term in the BAT conclusions would ensure
consistency, clarity and avoid possible conflicts.
  The word “safer” in the expression “safer alternative to hazardous chemicals” seems
redundant and it is not clear what it compares to.
  The use of enzymes as substitutes  for other chemicals is mentioned in a  number of
other BAT (BAT 15, BAT 37, BAT 39 and BAT 48) and it is therefore not necessary
to repeat it here.

Point VI
  Point  VI  is  about  goals  and  action  plans  to  reduce  the  use  of  hazardous  chemicals
whereas  point  I  is  specific  to  the  procurement  policy;  these  points  are  therefore  not
equivalent. This being said, both points are indeed connected as point I would be one
way to reduce the use of hazardous substances (another way could be for example to
change  processes  or  process  liquor)  and  it  would  bring  clarity  to  bring  both  points
together.
  The  aim  of  the  CMS  is  to  reduce  the  use  of  hazardous  substances,  which  in  turn
reduces the emissions of hazardous substances. The use of less hazardous substances
is one of the criteria listed in Annex III to the IED for determining BAT.

Point VII
  The reuse of process liquor is already  mentioned in BAT 15. The disposal of spent
process  liquor  chemicals  as  waste  is  covered  by  BAT 28  as  is  the  disposal  of  any

8 Guidance on Information Requirements and Chemical Safety  Assessment, Part D: Framework for  exposure assessment, ECHA
2016
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other  waste.  A  cross-reference  in  BAT 28  could  be  helpful  to  highlight  the
relationship between both BAT.
  Concerning  the  return  of  process  chemicals,  this  does  indeed  refer  to  the  unused
process chemicals mentioned in BAT 20.

Criteria for selecting process chemicals and their suppliers
  While examples of certification schemes and standards could helpfully  complement
the description of BAT 13, it seems difficult to promote commercial tools in a legal
text such as BAT conclusions. However, such examples are given in Chapter 4 of D1.
  A ‘positive list’ of chemicals is indeed a tool used by some certification bodies but it
does not seem necessary to detail those tools in the BAT conclusions. This being said,
Chapter 4 of D1 could usefully be complemented with this information.

General comment
  Concerning the restructuration of the CMS, the proposed order brings improved logic
to the order of the CMS features as these features go from management techniques to
the selection of chemicals, identification of emission pathways of substances used and
finally  techniques  for  handling  and  storage  of  chemicals.  The  setting  of  goals  and
action plans to reduce the use of hazardous substances seems however to precede the
procurement policy, which is one action for achieving the objective.
  Concerning  the  proposed  BAT  statement,  the  deletion  of  the  words  “all  of”  may
undermine the fact that all features are to be used and is not in line with the wording
of the EMS (BAT 1).
  Concerning  the  proposed  additional  point  about  the  emission  factor  concept,  this
element  is  already  mentioned  in  D1  as  one  possible  selection  criteria  for  process
chemicals which will have reduced emissions to air. Making a separate point for this
method could give the impression that only this method may be used.
  Concerning the proposed additional point about the eliminability and ecotoxicity of
process  chemicals,  these  are  indeed  important  characteristics  to  consider  for  the
selection of chemicals and could be added in point I as examples of selection criteria
in  addition  to  the  emission  factor  concept  for  emissions  to  air.  Making  a  separate
point  for  this  could  give  the  impression  that  only  those  characteristics  are  to  be
considered.
  Concerning the proposed wording of points I, V, VI, VIII and IX, see the assessment
of the corresponding points above.
  To  replace  “hazardous  chemicals”  with  “hazardous  substances”  throughout  the
document and to add this term in Definitions.
  To define the term “substances of very high concern” in Definitions and to use this
term throughout the document (e.g. in BAT 4 and BAT 13).
  To restructure the bullet points indicating the main CMS elements (bullet points I, VII
and VIII) and the elements of the selection of process chemicals (bullet points II, III,
EIPPCB
IV and V).
proposal:
  To complement the wording of points I, VI and VII.
  To reformulate point IV and point V.
  To  add  the  reuse  and  recovery  of  chemicals  to  elements  considered  in  selection  of
chemicals.
  To specify the role of the chemical inventory.
  To complement Chapter 4 of D1 with information about positive lists of chemicals.

Location in
P. 732 – Section 5.1.5 – BAT 14
D1:
BAT  14.  In  order  to  improve  the  overall  environmental  performance,  BAT  is  to
elaborate  and implement  a chemicals inventory and tracking system as  part of the
CMS (see BAT 13).
Current

text in D1:
Description
The chemicals inventory and tracking system is computer-based and contains information
about:
  the identity of the process chemicals;
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  the  quantities  and  location  of  the  process  chemicals  procured,  recovered  (see
BAT 15 f), stored, used and returned to suppliers;
  the characteristics of process chemicals including properties with adverse effects on
the environment and/or human health.

BAT statement
  Delete  “tracking  system”  as  the  meaning  is  unclear  and  replace  it  with  “electronic
tool for the chemical inventory lists” (DE 185).
  Delete  “tracking  system”  as  the  meaning  is  unclear  and  replace  it  with  “assess  the
partitioning  of  process  chemicals  in  the  environmental  compartments  (air,  water,
waste, product)” (DE 385).
  Delete “ tracking system” as a chemical tracking system provides no improvement of
environmental performance. The chemical inventory and knowledge of chemicals that
Summary
are waste-water- or air-relevant is sufficient (EURATEX 114).
of

comments:
Description
  Clarify  the  characteristics  of  the  process  chemicals  by  “the  physical  and  chemical
data  of  process  chemicals  (e.g.  solubility,  vapour  pressure,  log  Kow),  data  on
ecotoxicity,  fate  and  behaviour  in  the  environment  (e.g.  biodegradation,
adsorption/desorption  coefficient,  mobility)  as  well  as  adverse  effects  on  human
health” (DE 385).
  Mention  that  the  main  source  of  information  for  the  process  chemicals  and  their
characteristics  is  the  Safety  Data  Sheet  (SDS)  (ES 15,  FR_A 11,  CEFIC 11,
EURATEX 102), in particular Section 2 and Section 9 of the SDS (CEFIC 11).
BAT statement
  The  wording  “tracking  system”  refers  to  the  locations  and  quantities  of  process
chemicals mentioned in the second bullet point. As this wording seems unclear and is
in any case covered in a bullet point, it is not necessary.
  The tracking of chemicals is more efficient when an electronic tool is used but the use
of a computer-based system is already mentioned in the BAT description and it does
not seem necessary to repeat it in the BAT statement.
  The  assessment  of  the  fate  of  process  chemicals  in  various  environmental
compartments  is  based  on  the  chemicals  inventory  but  is  not  part  of  the  inventory
EIPPCB
itself. This assessment is part of BAT 13.
assessment:
Description
  According  to  D1,  information  mentioned  in  the  first  and  third  bullet  points  of  the
BAT description is indeed to be found in the Safety Data Sheet (SDS) but also in the
Technical Instruction Sheets and it could be useful for the reader to add a reference to
these documents.
  Concerning the proposed wording for the BAT description, some additional examples
of characteristics of the process chemicals could indeed bring further guidance to the
users of the BAT conclusions.
  To remove “tracking system” from the BAT statement.
EIPPCB
  To add a reference to SDS and to Technical Instruction Sheets in the BAT description
proposal:
as well as additional examples of characteristics of the process chemicals.
  To add some examples of physico-chemical and environmental properties.

1.4.5.2
Techniques for reducing the consumption of chemicals

Location in
P. 733 – Section 5.1.5 – BAT 15
D1:
BAT 15. In order to reduce the consumption of chemicals, BAT is to use all of the
Current
techniques given below.
text in D1:

Technique
Description
Applicability
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This includes:
  regularly  reviewing  the  formulation  of
Reduction of the
process chemicals and liquors;
Generally
a.  n
eed  for  process
  using  demineralised  water  in  the  applicable
chemicals
processes  to  reduce  the  need  for
complexing agents;
  production optimisation (see BAT 9 b).
The  applicability
Enzymes  are  selected  (see  BAT 13)  and  may  be  restricted
Treatment
of  used  to  catalyse  the  reactions  with  textile  by
product
b.

textile  materials  materials  to  lower  the  consumption  of  specifications  or
with enzymes
process  chemicals  (e.g.  in  desizing,  the  availability  of
bleaching and/or washing).
suitable enzymes
Automatic
Automatic  systems  for  weighing,  dosing,
systems
for  dissolving,  measuring  and  dispensing
preparation  and  which  ensures  precise  delivery  of  process
c.  d  osing
of  chemicals  and  process  liquors  to  the
process
production machines.
chemicals
and  See BAT 3.
process liquors
Optimisation  of
Generally
the  quantity  of
d.

See BAT 9 d.
applicable
process
chemicals used
Reuse
of
e.

See BAT 9 i.
process liquor
Recovery and
Residual  process  chemicals  are  recovered
use of leftover
(e.g.  by  thoroughly  purging  pipes  or
f.

process
completely  emptying  packaging)  and  used
chemicals
in the process.

General comment about BAT 15
  Delete  BAT 15  as  it  is  a  repetition  of  BAT 3,  BAT 9  and  BAT 28  or  it  should  be
contained in the Chemicals Management System (CMS) (DE 415).

BAT statement
  Change  the  environmental  objective  of  the  BAT  from  the  reduction  of  use  of
hazardous  chemicals  to  the  reduction  of  emissions  of  hazardous  chemicals  as  the
reduction of use does not have necessarily an environmental impact (CEFIC 12).

Technique a.
  Change the name of technique a. to reduction of chemicals consumption per tonne of
textiles (CEFIC 12).
  Delete  technique  a.  because  the  first  and  third  points  are  very  generic  and  already
Summary
covered.  Moreover,  concerning  the  second  point,  demineralised  water  is  not  widely
of
used but instead softened water (FR_A 50).
comments:
  Delete  the  second  point  as  the  use  of  demineralised  water  is  not  needed  when  the
incoming water is already very soft (IT 42).
  Replace the  use of demineralised  water  with  the  use  of  water softened  with  an  ion
exchanger.  Softened  water  is  sufficient  to  reduce  the  need  for  complexing  agents.
Demineralisation produces double the amount of waste baths from the regeneration of
the ion exchanger (DE 313, CZ_B 6, EURATEX 103).
  Delete the reference to demineralised water as the washing capacity of demineralised
or  softened  water  is  worse  than  that  of  "hard"  water  due  to  lack  of  calcium  and
manganese (EURATEX 156).
  Change  the  applicability  of  technique  a.  to  reflect  that,  depending  on  technical
feasibility and contamination of liquors, complexing agents might still be needed (i.e.
if the use of ion exchangers is not possible) (DE 313).

Technique b.
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  Specify the applicability restriction related to the product specifications by referring
to Section 4.1.6.4 of D1 (EEB 107).

Technique c.
  Change  the  applicability  to  standardised  processes  (e.g.  pretreatment  processes)  in
new  plants  or  major  upgrades  of  plants  because  the  technique  is  not  feasible  in
existing plants and it is not feasible for companies using hundreds of different liquors
(FR_A 51).
  Change  the  applicability  to  new  plants  and  major  plant  upgrades  as  the  technique
implies a new piping system from the new preparation system to every machine that
uses the liquor (IT 20).
  Change the applicability because  the use of this technique  may be restricted by the
size of the company or of the process (EURATEX 104).

Technique f.
  Change the applicability because the recovery and use of leftover chemicals may be
restricted  by  the  storage  life  and  the  presence  of  impurities  (CEFIC 32,
EURATEX 105).
  Add at the end of the description “whenever possible” as the collected chemicals may
need to be treated as waste (SE 23).
General comment about BAT 15
  The  objective  of  BAT 15  is  to  give  in  one  place  an  overview  of  the  techniques  to
reduce  the  quantity  of  chemicals  used.  BAT 15  contains  cross-references  to  other
BAT  when  these  BAT  have  multiple  benefits.  For  example,  BAT 9b,  BAT 9d  and
BAT 9i  allow  the  reduction  of  water  consumption  and  waste  water  generation  but
also the reduction of the consumption of chemicals.
  Deleting  BAT 15  would  lead  to  a  loss  of  information  about  the  reduced  use  of
complexing  agents  and  about  the  use  of  enzymes  which  is  proposed  to  be  removed
from BAT 13 (see Section 1.4.5.1 about BAT 13).

BAT statement
  The criteria for determining BAT do not concern only emissions to the environment.
The  reduced  consumption  of  chemicals  also  addresses  the  following  aspects,  which
are listed in Annex III to the IED as criteria for determining BAT:
o  the use of less hazardous substances;
o  the consumption of raw materials used in the process.
  It would therefore be limiting to change the environmental objective of the BAT to
the reduction of emissions only.

Technique a.
EIPPCB
  Technique a. aims to reduce the need for process chemicals, which in turn will reduce
assessment:
the consumption of chemicals, be it specific consumption or overall consumption. A
reference to specific consumption does not seem necessary.
  It could be clarified that not only is it necessary to review the formulation of process
chemicals and liquors, but also to optimise the formulation of process chemicals and
liquors.
  BAT 15 is structured in such a way that technique a.sets general techniques to reduce
the  need  for  process  chemicals  while  the  other  techniques  are  more  specific;  this  is
why  the  first  and  third  bullet  points  of  technique  a.  are  generic.  In  this  context,  the
second bullet point seems too specific and could be moved into a separate technique.
  The  description  of  the  technique  in  Section  4.4.7.2  in  Chapter 4  of  D1  refers  to
softened water and not demineralised water as a way to reduce the use of complexing
agent.
  No  information  has  been  made  available  about  the  lower  washability  of  softened
water.
  It is not clear in which cases the use of an ion exchanger would not be possible.

Technique b.
  Section 4.1.6.4 of D1 is not explicit as to which product specifications may limit the
use  of  enzymes.  Rather  than  the  product  specifications,  it  seems  that  the  limiting
factor is the availability of the enzymes for the given treatment and textile material.
  During the 2nd Data Assessment Workshop held on 21-23 October 2020, EURATEX
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clarified  that  enzymes  do  not  bleach,  they  are  used  in  pretreatment  to  improve  the
bleaching.

Technique c.
  According to Section 4.1.6.7 of D1, the size and the age of the plant do not seem to
represent a limitation to the applicability of automated dosing and dispensing systems
in general. However, the following limitations are listed and could be reflected in the
BAT conclusions:
o  space availability in existing plants, especially for the automation of dyes;
o  dosing  systems  based  on  the  colour-on-demand  principle  and  automated
laboratories are still very expensive and as a consequence more suitable for
large installations;
o  high  number  of  dyes  due  to  lack  of  space  and  the  higher  investment  costs
required,  where  the  plant  may  decide  to  automatise  the  dyes  with  higher
consumption and leave the others for manual dosing and dispensing;
o  long piping length may be uneconomical and environmentally controversial
for small batches (because the amount of process liquor in the pipes may be
higher than the amount actually needed).

Technique f.
  The  residual  process  chemicals  contained  in  process  pipes  may  indeed  be
contaminated, which could limit the degree to which they are used, as for water reuse
(see BAT 9). In that case, the contaminated process chemicals may need to be treated
by waste.
  Concerning the shelf life of the process chemicals, this could indeed limit the degree
of reuse of the chemicals, as mentioned in BAT 44.
  To move the use of demineralised water from technique a. into a dedicated technique
a1.
EIPPCB
  To refer to softened water instead of demineralised water.
proposal:
  To change the applicability restriction of technique (c).
  To add a reference to the contaminated process chemicals and their perishability in
technique (f).

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1.4.5.3
Techniques for preventing or reducing emissions to water of poorly
biodegradable substances

Location in
P. 733 – Section 5.1.5 – BAT 16
D1:
BAT 16.  In order  to prevent or  reduce emissions to water of poorly biodegradable
substances, BAT is to use all of the techniques given below.

Technique
Description
Applicability
Substitution  of  Alkylphenols  and  alkylphenol  ethoxylates
alkylphenols
(AP/APEO)
are
substituted
by  Generally
a.

and  alkylphenol  biodegradable  surfactants,  e.g.  alcohol  applicable
ethoxylates
ethoxylates (AE).
Complexing  agents  containing  phosphorus
(e.g.  triphosphates)  or  nitrogen  (e.g.
polycarboxylic acids such as EDTA, DTPA
Substitution  of  or  NTA)  are  substituted  by  biodegradable
substances, e.g:
Current
phosphorus-  or
The  applicability
text in D1:
nitrogen-

may  be  restricted
b.

  polycarboxylates  (e.g.  polyacrylates
containing
and  copolymers  of  acrylic  and  maleic  by
product
complexing
acids);
specifications
agents
  hydroxy
carboxylic
acids
(e.g.
gluconates, citrates);
  sugar-based acrylic acid copolymers.
Substitution  of
The  applicability
mineral-oil-
Mineral-oil-based  antifoaming  agents  are  may  be  restricted
c.  b  ased
substituted  by  biodegradable  substances,  by
product
antifoaming
e.g. silicone-based antifoaming agents.
specifications
agents

General comment about BAT 16
  Add techniques on chemicals with poor biodegradability and update the information
on the substitutes. Include techniques from other BATs for the selection of chemicals
with lower risks or chemicals which are biodegradable/bioeliminable (DE 391).

Technique a.
  Mention  in  the  technique  description  that  the  use  of  AP/APEO  is  restricted  by
REACH (DE 391).

Technique b.
  Change the applicability to generally applicable as the restriction proposed in D1 does
not seem justified (DE 391, EEB 108).
  Add in the technique description the following substitutes (DE 391):
Summary
o  methylglycinediacetic  acid  (MGDA),  L-glutamic  acid  N,N-diacetic  acid
of
(GLDA)  and  (N-(1,2-dicarboxyethyl)-D,L-aspartic  acid  (IDS)  which  are
comments:
biodegradable;
o  phosphonates  proven  to  be  highly  eliminable  (e.g.  ATMP,  DTPMP  and
HEDP).

Technique c.
  Add  in  the  technique  description  that  silicone-based  antifoaming  agents  have  a
minimised content of silicone cyclic substances (D4, D5 and D6) (DE 391).
  Add compounds based on synthetic ester oils as possible substitutes (DE 391).
  Specify the applicability clause as follows: “For instance, silicone-based antifoaming
agents cannot be applied for all kind of coating processes. The use of silicone can be
restricted  due  to  depositions  in  the  textile  finishing  equipment  such  as  dyeing
machines.” (DE 391).
  Delete the reference to silicone because silicone contaminates the machines and the
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textile and can have a negative effect on subsequent processes (EURATEX 115).
  Change the applicability to generally applicable as the restriction proposed in D1 does
not seem justified (EEB 109).

Additional techniques
  Add the following techniques (DE 391):

Waiving of brominated flame
Prevention of use
retardants as restricted by EU
Generally
d.  of brominated
REACH Annex XVII and EU POP
applicable
flame retardants
Regulation.
Not applicable for
personal protection
equipment where
the highest levels of
Prevention of use
Finishing without PFAS for durable
repellency are
of per- and
water repellency for ordinary apparel
required to
e.
polyfluorinated
textiles and outdoor textiles except
safeguard the user.
alkylated
for anticipated derogations under EU
and for certain
substances (PFAS)
law.
technical textiles
(e.g. temperature-
resistant bag filter
fabrics)
Generally
applicable. There
are alternative
Waiving of use of chromium VI
Prevention of use
techniques and
f.
compounds for dyeing of wool (after
of Chromium VI
alternative dyes
chroming process).
available to reach
the required deep
shades.
Use of sizing
agents and
mixtures of sizing
Mixtures of starch, starch
agents fulfilling an
derivatives, polyvinyl alcohol,
Generally
g.  elimination rate
polyacrylates, carboxymethyl
applicable
80 % within 28
cellulose and other sizing agents can
days according to
fulfil the elimination rate of 80 %
OECD 302B (EN-
ISO 9888)
Use of detergents
and mixtures of
detergents
fulfilling a
Generally
h.

biodegradation rate
applicable
of 70 % within 28
days according to
OECD 301A-F ()
Waiving of the use of all esters of
orthophthalic acid (phthalates), e.g.
as additive to plastics to increase
Prevention of use
flexibility, to facilitate moulding of
Generally
i.
of phthalates
plastic by decreasing its melting
applicable
temperature. In flexible plastic
components (e.g. PVC), print pastes,
adhesives and polymeric coatings
Prevention of use
Waiving of the use of UV absorbers
Generally
j.
of specific UV
UV 320, UV 327, UV 328, UV 350.
applicable
absorbers

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General comment about BAT 16
  Concerning  the  content  of  the  proposed  additional  techniques,  see  the  assessment
below.
  Concerning the grouping of all BAT related to the selection of chemicals in BAT 16,
this concerns in particular the proposed technique d. which is related to BAT 49b, the
proposed technique e. which is related to BAT 50, the proposed technique f. which is
related  to  BAT 41c  and  the  proposed  technique  g.  which  is  related  to  BAT 32a.  As
BAT 16  concerns  the  biodegradability  of  the  substances  used,  this  option  would
narrow down the focus of BAT 49b, BAT 50 and BAT 32a which also address other
aspects (toxicity, washability, etc.). Concerning the proposed technique f., the hazards
related  to  chromium  VI  are  not  limited  to  its  biodegradability  but  also  concern  its
(eco)toxicity and its CMR properties.

Technique a.
  The scope of the proposed BAT  conclusions states that the BAT conclusions apply
without prejudice to other relevant legislation such as REACH, CLP and BPR. It does
not  seem  necessary  to  indicate  the  status  of  the  substances  cited  in  the  BAT
conclusions according to this legislation. In addition, this status may evolve over the
lifetime of the BAT conclusions.

Technique b.
  Concerning the applicability of this technique, indeed there is no particular limitation
mentioned in Chapter 4 of D1.
  Technique  b.  focuses  on  substitutes  which  are  biodegradable  and,  according  to
Section 8.5 of D1, phosphonates are bioeliminable but not biodegradable. This can be
clarified in the title of the technique.
  MGDA,  GLDA  and  IDS  are  readily  biodegradable9.  It  is  not  clear  if  the
EIPPCB
compounds used in the TXT sector are in the form of acid or salt.
assessment:
  The compounds EDTA, DTPA or NTA can be classified under the group of amino
polycarboxylic acids.
  Gluconates and citrates are salts generated from the hydroxy carboxylic acids.

Technique c.
  In  March  2020,  SEAC  (Committee  for  Socio-economic  Analysis)  adopted  its  final
opinion10 supporting ECHA’s proposal to restrict the placing on the market of D4, D5
and  D6  as  substances,  as  constituents  of  other  substances,  or  in  mixtures  in  a
concentration  equal  to  or  greater  than  0.1  %  weight  by  weight  of  each  substance.
Therefore,  it  does  not  seem  necessary  to  mention  D4,  D5  and  D6  in  the  BAT
conclusions  as  the  use  of  these  substances  will  be  regulated  in  the  coming  months.
This could be added in the body of D1 though for information purposes.
  Synthetic ester oils are mentioned in BAT 33 as a possible substitute for mineral oil
used for spinning and knitting and it would be consistent to mention them here also.
  According to Section 4.1.6.8.3 of D1, the  use  of silicone  leads to a  risk of silicone
spots  on  the  textile  and  silicone  precipitates  in  the  machinery,  which  could  be
reflected in the applicability of this technique.
  No information has been made available about the impact of silicone on some coating
processes.
  The  product  specifications  mentioned  in  the  applicability  restriction  refer,  for
example,  to the automotive industry  where silicone cannot  be used, as  mentioned in
Section 4.1.6.8.3 of D1. However, after verification with the automotive industry, it is
not clear what the automotive-specific restrictions are.

Additional techniques
Proposed technique d.
  The proposal consists of banning the use of brominated flame retardants whose use is
restricted  by  the  REACH  Regulation  and/or  banned  by  the  POPs  Regulation.  The

9 Green Processes: Designing Safer Chemicals, John Wiley & Sons, 2014
10 https://echa.europa.eu/fr/registry-of-restriction-intentions/-/dislist/details/0b0236e181a55ade
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link to page 80 Background paper – Final meeting for the review of the TXT BREF
added value of this technique would therefore be very limited and may not be entirely
in  line  with  the  REACH  Regulation  as  the  REACH  restrictions  may  contain
exemptions.

Proposed technique e.
  Per- and polyfluorinated alkylated substances (PFAS) include a wide variety of more
than 3 000 compounds11.
  Perfluorooctanoic acid (PFOA) and its salts are listed in Annex XVII to the REACH
Regulation and from 4 July 2020 shall not be manufactured, or  placed on the market
as substances on their own or be used in the production of, or placed on the market in
another substance, as a constituent, a mixture, an article, in a concentration equal to or
above 25 ppb by weight of PFOA including its salts or 1 000 ppb by weight of one or
a combination of PFOA-related substances.
  Perfluorooctane sulphonic acid and its derivatives (PFOS) are prohibited by the POPs
Regulation. Some exemptions are:
o  concentrations of PFOS equal to or below 0.001 % by weight when it occurs
in substances or in preparations;
o  concentrations  of  PFOS  in  semi-finished  products  or  articles,  or  parts
thereof,  if  the  concentration  of  PFOS  is  lower  than  0.1 %  by  weight
calculated  with  reference  to  the  mass  of  structurally  or  micro-structurally
distinct parts that contain PFOS or, for textiles or other coated materials, if
the amount of PFOS is lower than 1 μg/m2 of the coated material.
  Adding a technique to ban the use of substances already subject to restrictions or to
prohibition does not seem necessary and may not be entirely in line with the REACH
Regulation.
  Concerning the other PFAS, no information has been provided as to why they are not
to be used.

Proposed technique f.
  Sodium  and  potassium  dichromate  are  “substances  of  very  high  concern”  listed  in
Annex  XIV  to  the  REACH  Regulation  and  the  use  of  these  substances  is  subject  to
authorisation. Therefore, adding a technique to ban their use does not seem necessary
and would not be in line with the REACH Regulation.

Proposed technique g.
  The proposed technique g. is based on BAT 32a in D1.
  It is not clear why galactomannans are proposed to be removed from the examples of
sizing chemicals with improved environmental performance.
  According  to  Section 8.3  of  D1,  carboxymethyl  cellulose  (CMC)  is  water-soluble.
CMC  is  mentioned  as  being  very  difficult  to  degrade  as  only  20  %  of  the  initial
amount is eliminated after 7 days. However it can be reduced after longer periods of
adaptation (> 4 weeks) and in favourable conditions (especially higher temperatures).
CMC  could  therefore  be  added  in  the  examples  of  sizing  chemicals  with  improved
environmental performance.
  Concerning the elimination rate of 80 % within 28 days according to EN ISO 9888,
see the assessment related to BAT 18 (Section 1.4.6.2).

Proposed technique h.
  According to Table 8.8 of D1, nearly all the types of surfactants which are used in the
textiles industry have a biodegradability higher than 70 %12 except APEO.
  The  substitution  of  APEO  by  biodegradable  surfactants  is  already  addressed  in
technique a.

Proposed technique i.
  Phthalates include a wide variety of different compounds.
  DEHP (bis- (2-ethylhexyl) phthalate), benzyl butyl phthalate (BBP), dibutyl phthalate

11  https://www.umweltbundesamt.de/themen/chemikalien/chemikalien-reach/stoffgruppen/per-polyfluorierte-chemikalien-pfc#was-
sind-pfc
12 According to test OECD 301E
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(DBP), dihexyl phthalate and diisobutyl phthalate (DIBP) are listed in Annex XVII to
the  REACH  Regulation  and  shall  not  be  used  as  substances  or  in  mixtures,  in
concentrations  greater  than  0.1 %  by  weight  of  the  plasticised  material,  in  toys  and
childcare articles.
  DEHP  is  also  listed  in  Annex  XIV  to  the  REACH  Regulation.  One  authorisation
granted  to  a  manufacturer  may  possibly  concern  the  textile  industry  (PVC-based
waterproof clothing and footwear).
  Seven  other  phthalates  are  listed  in  Annex  XIV  to  the  REACH  Regulation:  benzyl
butyl  phthalate  (BBP),  dibutyl  phthalate  (DBP),  dihexyl  phthalate,  diisobutyl
phthalate  (DIBP),  diisopentyl  phthalate,  bis(2-methoxyethyl)  phthalate,  dipentyl
phthalate and N-pentyl-isopentylphthalate. No application for authorisation has been
submitted so far for uses in the textile sector.
  Adding a technique to ban the use of substances already subject to authorisation does
not seem necessary and may not be entirely in line with the REACH Regulation.
  D1  mentions  that  DEHP  may  be  used  as  a  dyeing  auxiliary  but  does  not  mention
other phthalates.
  No information has been provided about the use of other phthalates and their possible
substitutes.

Proposed technique j.
  UV 320 (2-benzotriazol-2-yl-4,6-di-tert-butylphenol), UV 327 (2,4-di-tert-butyl-6-(5-
chlorobenzotriazol-2-yl)phenol),
UV 328
(2-(2H-benzotriazol-2-yl)-4,6-
ditertpentylphenol)  and  UV 350  (2-(2H-benzotriazol-2-yl)-4-(tert-butyl)-6-(sec-
butyl)phenol)  are  “substances  of  very  high  concern”  listed  in  Annex  XIV  to  the
REACH  Regulation  and  their  use  is  subject  to  authorisation.  Therefore,  adding  a
technique to ban their use does not seem necessary and would not be in line with the
REACH Regulation.
  To amend the title of technique b.
  To add examples of possible substitutes in technique b.
EIPPCB
  To change the applicability restriction of technique b to generally applicable.
proposal:
  To complement the description of technique c.
  To modify and complement the applicability restriction of technique c.
  To add a reference to carboxymethyl cellulose (CMC) in BAT 32a.

1.4.6
Emissions to water

1.4.6.1
Techniques for reducing the waste water volume, the pollutant
loads discharged to the waste water treatment plant and the
emissions to water

Location in
P. 734 – Section 5.1.6 – BAT 17
D1:
BAT 17. In order to reduce the waste water volume, the pollutant loads discharged
to  the  waste  water  treatment  plant  and  the  emissions  to  water,  BAT  is  to  use  an
integrated  waste  water  management  and  treatment  strategy  that  includes  an
appropriate combination of process-integrated techniques, techniques to recover and
Current
reuse process liquors, and treatment techniques (see BAT 18 and BAT 19).
text in D1:

Description
The  integrated  waste  water  management  and  treatment  strategy  is  based  on  the
information provided by the inventory of inputs and outputs (see BAT 2).
Whole BAT
  Integrate  BAT 17  with  BAT 2  and  BAT 9  to  avoid  repetition,  ease  the
Summary
implementation  and  streamline  general  requirements  for  waste  water  management.
of
The  relations  of  waste  water  management  and  treatment  strategy  in  BAT 17,  the
comments:
inventory  of  water  inputs  and  outputs  in  BAT 2,  and  the  water  management  plan  in
BAT 9  need  to  be  clarified.  Since  both  BAT 2  and  BAT 9  are  part  of  the
environmental  management  system  (BAT 1),  it  is  unclear  if  the  waste  water
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management  and  treatment  strategy  of  BAT 17  is  also  part  of  the  EMS.  Also,  it  is
unclear  whether  the  inventory  of  water  inputs  and  outputs  (BAT 2)  is  not  already
covered by the water management plan (BAT 9) (AT 40).
  Delete BAT 17 as it is part of BAT 18 (DE 267).

BAT statement
  Change  the  statement  to  highlight  the  need  for  concentrated  bath  and  pastes  to  be
collected, recovered/reused or handled (e.g. disposed) as waste containing hazardous
chemicals (SE 15).

Description
  Clarify  that external  waste water treatment can be done by an external waste water
treatment plant (WWTP) (EURATEX 16).
Whole BAT
  A technique can fulfil several environmental objectives in different BAT conclusions.
The  environmental  objective  of  BAT 2  is  to  improve  the  overall  environmental
performance  of  the  plant,  of  BAT 9  to  reduce  water  consumption  and  waste  water
generation  and  of  BAT 17  to  reduce  the  waste  water  volume,  the  pollutant  loads
discharged  to the  waste  water treatment plant and the emissions to  water.  These are
different aspects of the plant’s environmental performance.
  The  issues  addressed  by  the  three  BAT  may  overlap  but  are  approached  from
different  perspectives  and  with  different  goals:  BAT 2  aims  to  ensure
data/information  collection  for  all  input/output  streams;  BAT 9  focuses  mainly  on
reuse/recovery/reduction  of  consumption  of  waters  and  process  liquors  (and
consequently on waste water reduction) and BAT 17 deals with strategy for reduction
or treatment of waste waters.
  An  integrated  waste  water  management  and  treatment  strategy  can  be  a  part  of  a
water  management  plan  (BAT 9a).  It  is  a  decision-making  tool  for  selection  of  the
optimal waste water treatment, used in an ongoing decision-making process (e.g. for
evaluation of the  waste  water treatment options and  the efficiency of  the techniques
used) of the environmental management system in an operating installation.
  Recovery/reuse of process liquors is addressed in BAT 9i. The cross-reference could
be added.
  BAT 2  already  cross-references  BAT 1  and  BAT 9  to  highlight  its  link  to  the
environmental  management  system  –  so  an  additional  reference  in  BAT  17i  is  not
needed.
EIPPCB
  BAT 17 is generic and BAT 18 is specific. BAT 17 aims at selection of techniques to
assessment:
either  reduce/reuse  process  liquor,  (pre)treat  it  as  waste  water  or  handle  it  as  waste
(see assessment below). BAT 18 sets further criteria for the pretreatment of effluents
of  spent  process  liquors  (i.e.  with  pollutants  that  cannot  be  adequately  treated  by  or
could harm the operation of a biological treatment).  Deleting BAT 17  would  reduce
the  flexibility  of  using  an  appropriate  combination  of  techniques  and  remove  the
process of their selection as an important decision-making tool.

BAT statement
  If  process  liquors  cannot  be  i)  reduced  by  process-integrated  techniques,  ii)
reused/recovered  or  iii)  treated  by  a  suitable  waste  water  pretreatment,  they  can  be
handled  as  waste  (e.g.  treated  or  disposed  of  off  site).  The  concentrated  process
liquors with recalcitrant and toxic pollutants are best  removed, treated or disposed of
from  the  common  waste  water  flow  (not  to  be  diluted  by  mixing  with  other  waste
water streams), thereby reducing the pollutant loads to be treated and discharged. This
could be mentioned in the BAT statement.
  Concentrated  baths  and  pastes  that  contain  recalcitrant  pollutants  are  addressed  in
BAT 18.

Description
  The use of off-site contractors to control the environmental impacts of the plant is an
implementation  decision  that  is  not  within  the  scope  of  the  BAT  conclusions  but  in
the  hands  of  the  operator  and  the  competent  authority.  The  alternative  of  off-site
treatment is mentioned in BAT 18.
EIPPCB
  To  restructure  the  text indicating the  order of priority and listing the  techniques  on
proposal:
separate lines.
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  To add cross references to other BAT to the techniques (e.g.  BAT 9i, BAT 38 and
others).
  To add as one of the techniques separation and pre-treatment or handling as waste of
concentrated waste water streams, which are the subject of BAT 18.

1.4.6.2
Techniques for reducing emissions to water

Location in
P. 734 – Section 5.1.6 – BAT 18
D1:
BAT  18.  In  order  to  reduce  emissions  to  water,  BAT  is  to  (pre)treat  waste  water
containing pollutants that cannot be treated adequately by a biological treatment.

Description
The  treatment  is  carried  out  as  part  of  an  integrated  waste  water  management  and
treatment strategy (see BAT 17) and is generally necessary to:

  protect the (downstream) biological waste water treatment against inhibitory or toxic
compounds;
  remove  compounds  that  are  insufficiently  abated  during  biological  waste  water
treatment  (e.g.  toxic  compounds,  poorly  biodegradable  organic  compounds,  organic
compounds that are present in high concentrations, or metals);
  remove compounds that could otherwise be stripped to air from the collection system
or during biological waste water treatment (e.g. sulphide);
Current
  remove  compounds  that  have  other  negative  effects  (e.g.  corrosion  of  equipment;
text in D1:
unwanted reaction with other substances; contamination of waste water sludge).

The treatment is carried out on site or off site. On-site treatment is generally carried out as
close as possible to the source in order to avoid dilution.

The  techniques  used  depend  on  the  pollutants  targeted  and  include  adsorption,  chemical
oxidation and chemical reduction (see BAT 19).

Waste water which may contain toxic or poorly biodegradable compounds includes:

  spent liquors from sizing, dyeing and finishing;
  spent printing pastes.

The  biodegradability  of  the  COD/TOC  content  of  the  waste  water  sent  to  biological
treatment is at least 80 %, monitored in accordance with the standard EN ISO 9888

BAT statement
  Change  the  BAT  statement  to  emphasise  the  minimisation  of  the  amount  of  waste
water,  and  to  focus  on  retaining  and  reusing  waste  waters  containing  pollutants  that
cannot be adequately treated by biological treatment (DE 267).

Introduction
  Change in the introductory sentence “generally necessary” to “aims at” to focus more
Summary
on technical features of the technique (FR_A 12).
of

comments:
First bullet point
  Reword the first bullet point to keep only the technical feature of technique, which is
treating/removing inhibitory or toxic compounds (FR_A 13).

Second bullet point
  In  the  second  bullet  add  the  reference  to  BAT 19  and  list  the  treatment  techniques
according  to  the  pollutants  they  are  relevant  for:  a)  chemical  oxidation,  chemical
reduction,  filtration,  adsorption  or  evaporation  for  poorly  biodegradable  organic
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compounds;  b)  adsorption,  precipitation,  chemical  oxidation,  chemical  reduction  for
organic compounds present in high concentrations; c) precipitation for soluble metals
or solid removal for metals bound to suspended solids (BE 17).
  In the second bullet point indicate that the metals are present in high concentrations.
Metals  come  from  dyes  but  pretreatment  is  needed  only  in  the  case  of  high
concentrations (EURATEX 17).
  In  the  second  bullet  specify  toxic/poorly  biodegradable  waste  water  streams’
concentrates  such  as  desizing  liquors,  residual  padding  liquors  from  continuous  or
cold  pad-batch  dyeing,  residual  printing  pastes,  residual  padding  liquors  from  final
finishing.  In  addition,  specify  that  they  need  to  be  pretreated.  A  concrete  wording
proposal is attached to the comment (DE 267).

On-site and off-site treatment
  Remove  the  sentence  stating  that  the  treatment  is  carried  out  on  site  or  off  site,
because it is inconsistent, the purpose of this  wording is not clear and has  no added
value (FR_A 15).

Treatment techniques
  Change  the  wording  “chemical  oxidation  and  chemical  reduction”  to  “chemical
oxidation  OR  chemical  reduction”,  because  they  are  opposite  reactions
(EURATEX 18).

Waste water streams concerned
  Move the paragraph listing poorly biodegradable compounds under the second bullet
as it deals with toxic or poorly biodegradable compounds (FR_A 14).
  Add  coating  pastes  next  to  printing  pastes  as  they  can  also  contain  toxic  or  poorly
biodegradable  compounds  and  are  used  in  larger  amounts  then  printing  pastes
(SE 16).
  Add that  individual  waste  water streams listed  here  need to be  collected separately
(segregated) (DE 267).
  Add  padding  liquors  from  continuous  or  cold  pad-batch  dyeing  and  final  finishing
(DE 267).

Level of biodegradability
  Add bioelimination (DE 290) or elimination (EURATEX 116) to biodegradability in
the last sentence of the description (DE 290, EURATEX 116).
  Clarify the regulatory status of the percentage, i.e. whether it is an indicative value,
BAT-AEPL or BAT-AEL, or delete it (FR_A 20).
  The monitoring standard is not consistent with BAT 7 (FR_A 20).
  Delete  the  last  sentence  because  no  information  has  been  collected  (i.e.  within  the
questionnaires)  regarding  the  level  of  biodegradability  of  the  COD/TOC  content  of
the waste water sent to biological treatment (IT 21).
  Provide justification for how the figure of 80 % was derived (UK 20).

Additional proposals
  Add  that  the  technique  is  not  applicable  for  commission  working  plants,  or
alternatively  that  it  is  applicable  only  to  new  plants  and  major  plant  upgrades.  The
reasons  are  high  costs  related  to  the  investment  in  (pre)treatment  techniques  and
difficult identification and separation of polluting waste water streams in commission
working plants (EURATEX 15).
  Add that for the applicability of this BAT the economical/technical feasibility should
be taken into account and demonstrated (EURATEX 19).
  Add  a  BAT  for  on-site  pretreatment  of  waste  water  streams  containing
organophosphorus  flame  retardants  (FR)  for  both  direct  and  indirect  discharges.  D1
gives confusing information:  that organophosphorus  FR  should be collected and  not
discharged (p. 806), that urban WWTPs should be equipped with appropriate tertiary
treatment for organophosphorus FR (p. 171). In addition, there is a general overview
of  techniques  that  can  be  used  to  remove  soluble,  non-biodegradable  contaminants,
such as organophosphorus FR (p. 425) (BE 19).

EIPPCB
BAT statement
assessment:
  BAT 9 and BAT 17 aim to reduce waste water generation or its volume by choice of
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various techniques. The focus of this conclusion is reducing emissions to water either
by pre-treatment.

Introduction
  The wording was used in BAT 11 of the CWW BAT conclusions. It is not clear why
rewording would be needed.

First bullet point
  The  bullet  expresses  the  important  goal  of  the  removal  of  inhibitory  or  toxic
compounds. The  wording  was used in BAT 11  of the  CWW BAT conclusions. It is
not clear why rewording would be needed.

Second bullet point
  The  individual  waste  water  treatments  that  may  abate  the  inhibitory  or  toxic
compounds  are  listed  in  BAT 19.  This  was  referenced  in  the  description  in  the
following paragraph (e.g. see Treatment techniques below).
  The main source of metals in the spent process liquors are dyes. This is indicated by
mentioning  spent  liquors  from  dyeing  in  the  listing  of  the  individual  waste  water
streams in the description below the bullets (e.g. see Waste water streams concerned).
  Repeating  the  individual  waste  water  streams  in  bullets  explaining  the  aim  of  the
pretreatment  would  complicate  the  text.  The  need  to  pretreat  at  source  to  avoid
dilution  is  explained  in  the  description  following  the  bullets.  The  alternative  to
pretreatment is handling these waste water streams as waste.

On-site and off-site treatment
  The  off-site  or  on-site  treatment  are  implementation  options  to  be  decided  by  the
operator  and  the  competent  authority  on  a  case-by-case  basis  to  comply  with  BAT-
AELs and local environmental constraints. Therefore, mention of these options can be
avoided in the description.

Treatment techniques
  The wording should be changed to indicate that either chemical oxidation or chemical
reduction is possible.

Waste water streams concerned
  The  paragraph  listing  the  waste  water  streams  concerned  could  be  moved  to  the
beginning  of  the  description.  It  does  not  seem  practical  to  merge  it  with  the  bullets
listing the aims of the treatment.
  Spent  coating  baths  could  be  added  to  the  list  of  waste  water  streams  similar  like
finishing baths.
  According to the data collection, out of 106 plants, only 6 (DE024, DE030, DE039,
DE049 FR130 and FR133) reported handling spent dyeing baths and padding liquors
as  waste  and  17  reported  treating  them  as  waste  waters;  10  plants  (DE022,  DE024,
DE025,  DE030,  DE032,  DE046,  DE047,  DE049,  FR135  and  SE119)  reported
handling  spent  finishing  baths  or  padding  liquors  as  wastes  and  8  reported  treating
them as waste waters.
  It  could  be  highlighted  that  individual  waste  water  streams  considered  in  this
conclusion need to be collected separately (segregated).
  Padding  liquors  from  continuous  or  cold  pad-batch  dyeing  and  finishing  could  be
added to the list of waste water streams.

Level of biodegradability
  Bioeliminability  seems  to  be  an  appropriate  parameter  in  relation  to  the  treatment
techniques  (adsorption,  chemical  oxidation  and  chemical  reduction)  proposed  to
remove the pollutants. The percentage of bioeliminability of the treated waste waters
is part of the BAT description (efficiency of the removal) and does not have the status
of a BAT-AE(P)L. The BAT-AE(P)Ls in the conclusions are clearly indicated as such
according to Implementing Decision 2012/119/EU.
  The monitoring standard for biodegradability and bioeliminability is EN ISO 9888 –
as also indicated in the table of BAT 7.
  The  fact  that  data/information  on  biodegradability  was  not  collected  via
questionnaires is not a reason for dismissing other sources available to the EIPPCB or
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expert opinion.
  The  bioeliminability  or  biodegradability  of  more  than  80 %  (e.g.  after  28  days  in
relation to the Zahn-Wellens test (EN ISO 9888) according to the OECD 301 test) is
considered  a  criterion  for  biodegradable/bioeliminable  substances  in  several  places
within D1 (e.g. Figure 4.35 in Section 4.1.3.2.1. Selection of sizing agents).

Additional proposals
  The  only  economic  information  on  costs  for  waste  water  treatment  techniques  was
provided  for  a  combination  of  techniques  called  Zero  Liquid  Discharge.  No
information on high costs of separation or treatment of  these waste  water streams in
commission  working  plants  was  provided,  which  makes  economic  assessment
difficult.
  The  plants  reporting  using  this  technique  demonstrate  the  technique’s
economic/technical feasibility. No other information enabling economic assessments
was provided.
Spent  finishing  liquors  would  include  the  waste  water  streams  containing
organophosphorus  flame  retardants  (FR).  The  waste  water  treatments  mentioned  in  this
conclusion  would remove organophosphorus FR  from the  waste  waters. This conclusion
is  valid  irrespective  of  the  type  of  discharge.  The  need  to  collect  ant  treat  these  waste
streams separately  from others could be reflected in  the  statement and  description of the
conclusion.
BAT statement
  To modify the statement to highlight the high pollutant loads of poorly biodegradable
compounds.

Description section
  To  put  the  list  of  the  waste  water  streams  considered  at  the  beginning  of  the
description.
EIPPCB
  To complement the list with spent dyeing, coating and finishing liquors.
proposal:
  To  indicate  that  these  streams  include  residual  padding  liquors  from  continuous
and/or cold pad-batch processes.
  In the statement on treatment, to indicate chemical oxidation and chemical reduction
techniques as alternatives (linking them  with ‘or), and to possibly add filtration and
precipitation.
  To  replace  ‘Biodegradability  of  the  COD/TOC  content’  with  ‘bioeliminability’  of
waste water streams sent to downstream biological treatment.

Location in
P. 735 – Section 5.1.6 – BAT 19
D1:
BAT  19.  In  order  to  reduce  emissions  to  water,  BAT  is  to  use  an  appropriate
combination of the techniques given below.

Technique (1)
Typical pollutants targeted
Applicability
Preliminary and primary treatment, e.g.
a.
Equalisation
All pollutants
b.
Neutralisation
Acids, alkalis
Physical separation (e.g.
screens, sieves, grit
Generally
Current
separators, grease separators,
Gross solids, suspended solids,
applicable
c.

text in D1:
oil-water separation,
oil/grease
hydrocyclones or primary
settlement tanks)
Physico-chemical treatment, e.g.
Adsorbable dissolved non-
d.
Adsorption
biodegradable or inhibitory
pollutants, e.g. AOX
Generally
Precipitable dissolved non-
applicable
biodegradable or
e.
Precipitation
inhibitory pollutants, e.g. metals,
phosphorus
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Oxidisable dissolved non-
f.
Chemical oxidation
biodegradable or inhibitory
pollutants, e.g. AOX, sulphide
Reducible dissolved non-
biodegradable
g.
Chemical reduction
or inhibitory pollutants, e.g.
hexavalent chromium (Cr(VI))
h.
Evaporation
Soluble contaminants
Biological treatment, e.g.
i.
Activated sludge process
Biodegradable organic
Generally
j.
Membrane bioreactor
compounds
applicable
k.
Anaerobic treatment
Nitrogen removal
Nitrification
may  not  be
applicable  in
the  case  of
high  chloride
concentrations
(e.g.
Nitrification/denitrification
above  10  g/l).
l.
(when the treatment includes
Total nitrogen, ammonia
Nitrification
a biological treatment)
may  not  be
applicable
when the
temperature
of  the  waste
water  is  low
(e.g. below 12
°C).
Solids removal, e.g.
m.  Coagulation and flocculation
n.
Sedimentation
Filtration (e.g. sand
Suspended solids and
Generally
o.
filtration, or membrane
particulate-bound metals
applicable
filtration)
p.
Flotation
(1) The descriptions of the techniques are given in Section 5.9.3.

Whole BAT
  Add technique 'boiling of effluent with caustic soda to destroy the permethrin' (used
in  Plant  UK123,  see  paragraph  4.1.7.3.4.1  of  D1)  because  of  its  performance  and
permethrin’s high toxicity to aquatic organisms (BE 29).
  Restructure the BAT to reflect the common sequences for textile-specific waste water
treatment  plants  (primary,  secondary,  tertiary  treatment  etc.),  including  textile-
specific  requirements  and  removal  efficiency.  Also,  add  examples  of  waste  water
treatment sequences. Proposals are attached to the comment13 (DE 268).
Summary
  Revise  the  table  substantially  because  the  currently  proposed  description  can  be
of
misleading  (i.e.  some  of  the  techniques  have  been  assigned  a  false  function  and
comments:
position in the sequence of downstream treatment operations). A proposal is attached
to the comment (CZ_B 19).
  Add zero liquid discharge (ZLD) to the list, together with information on its severe
cross-media effects (see final report on EU project EColoRO) (DE 392).

Biological treatment, e.g.
Technique k.
  Indicate  that  the  applicability  of  anaerobic  treatment  may  be  restricted  by  the

13 Schönberger, H., Technique combinations to meet the ambitious ZDHC Wastewater Guidelines, Proceedings of the Colloquium
on  Textile  Wastewater  Management  2018-09-18/Integrated  Best  Available  Wastewater  Management  in  the  Textile  Industry,
Vulkan-Verlag GmbH, Essen (2018) p.35 – 70
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composition of waste water (EURATEX 20).

Solids removal, e.g.
Technique o.
  Add  the  following  specific  membrane  filtration  techniques:  nanofiltration,  reverse
osmosis, ultrafiltration and microfiltration (BE 26).

Whole BAT
  The technique 'boiling of effluent with caustic soda to destroy the permethrin' (used in
Plant UK123) is considered to be an example of chemical oxidation treatment and is
mentioned in Section 4.1.7.3.4.1 of D1. Pesticides could be mentioned as an example
of typical pollutants targeted by the chemical oxidation technique.
  The removal efficiencies of individual techniques are given in Chapter 4 of D1; they
are indicative of potential environmental performance in any sector (not just textiles).
According to the data collection, only 16 out of 1 213 data sets for emissions to water
reported  the  actual  removal  efficiencies  in  the  real  plants  (see  Section  3.4.1  of  D1).
The  BAT-AELs  are  typically  considered  a  sufficient  regulatory  tool  to  ensure
appropriate  removal  of  pollutants.  High  removal  efficiencies  are  exceptionally  used
instead of BAT-AELs for regulating cases of high water recycling and consequently
high pollutant load build-up.
  The  BAT  statement  instructs  the  operator  and  competent  authority  that  the
appropriate  combination  of  techniques  listed  in  the  table  is  to  be  selected.  The
groupings of techniques (e.g. primary, secondary, tertiary treatment etc.) as proposed
in the comments could be helpful for the implementation.
  The  textile-specific  pollutants  targeted  related  to  specific  waste  water  treatment
techniques could be amended.
  The  Zero  Liquid  Discharge  approach  to  waste  water  treatment  and  recycling  is  a
EIPPCB
combination  of  techniques  already  presented  in  the  table.  Many  approaches  using
assessment:
different  combinations  and  variations  of  techniques  from  the  table  are  presented  in
Section 4.1.7.4 of D1.

Biological treatment, e.g.
Technique k.
  The  typical  pollutants  removed  from  the  effluents  by  the  treatment  techniques  are
indicated  in  the  table.  The  choice  of  appropriate  techniques  to  remove  certain
pollutants is not considered an applicability restriction.
  As  indicated  in  Section  4.1.7.3.5.2  of  D1,  the  technique  is  typically  used  as  a
(pre)treatment for waste water which is characterised by a high organic load (> 2 g/l)
and  a  more  or  less  constant  quality.  It  is  therefore  used  mostly  in  the  sectors  with
effluents  with  consistently  high  BOD  loads.  In  the  textile  sector,  anaerobic
bioreactors  are  used  in  combination  with  activated  sludge  treatment  to  treat  textile
effluents  with  a  high  COD  concentration  and  dyestuff  pollutants.  According  to  the
data collection, Plants CZ019 and FR134 indicated using the technique.

Solids removal, e.g.
Technique o.
  Specific  membrane  filtration  techniques:  nanofiltration,  reverse  osmosis,
ultrafiltration and microfiltration are already listed in the description of the membrane
filtration technique in Section 5.9.3.
  To  restructure  the  table  to  follow  the  steps  (e.g.  pre-treatment,  primary,  secondary,
EIPPCB
tertiary, advanced) in the waste water treatments typical for textile sector.
proposal:
  To  add  examples  of  typical  pollutants  targeted  by  specific  waste  water  treatment
techniques.

1.4.6.3
BAT-AELs for direct discharges to a receiving water body

Location in
P. 735 – Section 5.1.6 – BAT 19 – Table 5.3
D1:
Current
Table 5.3: BAT-associated  emission  levels  (BAT-AELs)  for  direct  discharges  to  a
text in D1:
receiving water body
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BAT-AEL (1)
Substance/Parameter
Activities / processes
(mg/l)
Adsorbable organically bound halogens
0.1–0.5
(AOX) (2)
All activities /
Chemical oxygen demand (COD) (3)
processes
40–120 (4)
Hydrocarbon oil index (HOI)
1–10
Pre-treatment and/or
dyeing of polyester
Antimony (Sb)
Finishing with flame
0.1–0.4
retardants using
antimony trioxide
Metals /
Dyeing with
metalloids
Chromium (Cr)
chromium-containing
0.01–0.3
dyes
Copper (Cu)
0.03–0.4
All activities /
Nickel (Ni)
0.01–0.5
processes
Zinc (Zn)
0.04–0.5
Dyeing with sulphur
Sulphide, easily released (S2-)
0.3–1
dyes
Total nitrogen (TN)
5–20 (5)
Total organic carbon (TOC) (3)
All activities /
13–40 (6)
Total phosphorus (TP)
processes
0.4–5
Total suspended solids (TSS)
5–45
(1) The averaging periods are defined in the general considerations.
(2) The BAT-AELs only apply when the substance/parameter concerned is identified as
relevant  in  the  waste  water  stream  based  on  the  inventory  of  inputs  and  outputs
mentioned in 0.
(3)  Either  the  BAT-AEL  for  COD  or  the  BAT-AEL  for  TOC  applies.  The  BAT-AEL
for TOC is the preferred option because TOC monitoring does not rely on the use of
very toxic compounds.
(4) The upper end of the BAT-AEL range may be up to 150 mg/l when the amount of
waste water discharged is less than 25 m3/t of treated textile materials.
(5) The BAT-AEL may not apply when the temperature of the waste water is low (e.g.
below 12 °C) for prolonged periods.
(6) The  upper  end  of  the  BAT-AEL  range  may  be  up  to  50 mg/l  when  the  amount  of
waste water discharged is less than 25 m3/t of treated textile materials.

The associated monitoring is given in 0.

General comments
  Derive  BAT-AELs  for  direct  discharges  to  a  receiving  water  body  based  on  the
reported  emission  data  of  the  direct  discharges,  because  indirect  discharges  do  not
implement an appropriate combination of the techniques to reduce emissions to water
for  direct  discharge  (e.g.  physico-chemical  treatment,  biological  treatment,  nitrogen
removal, solids removal); see also comments BE 21 and BE 22 (BE 3).
  Express BAT-AELs as specific loads in kg/ton of treated textile or add an appropriate
expression/factor  (×  m3/t)  for  all  BAT  AELs.  Many  important  BATs  which  reduce
water  and  energy  consumption  simultaneously  increase  the  concentration  of
pollutants (see also comment SE 40) (SE 26).
Summary
  In the interest of transparency, explain the methodology of deriving BAT-AELs either
of
within the BREF or in a separate document (UK 21).
comments:

Additional parameters
  Set a BAT-AEL range for BOD at 5-10 mg/l, because it shows the efficiency of the
WWTP. Also, the collected data indicate that the range is valid (SE 28).
  Set  an  upper  end  of  the  BAT-AEL  range  for  colour  for  dyeing  activities  as  1/30
dissolution  (ES  38);  or  as  spectral  absorption  coefficients  at  436  nm  (yellow  range)
7 m-1;  525  nm  (red  range)  5 m-1;  620  nm  (blue  range)  3 m-1  (DE  273).  Colour  in
discharge  could  have  a  negative  impact  on  water  bodies  and  has  a  high  public
response (ES 38, DE 273).
  Set BAT-AEL ranges for the following:
o
NH4-N with the upper end of the range up to 10 mg/l, because it is toxic to
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fish.
o
Toxicity  with  the  option  to  use  one  or  a  combination  of  different
measurement methods. For EN ISO 15088 set the upper end of the range up
to 2 mg/l. It is important to control the toxicity for directly discharged waste
water (DE 273).
  Set  the  BAT-AEL  range  for  nonylphenol  to  0.0002-0.005  mg/l  (=  0.2-5  µg/l)
Nonylphenol is a substance of environmental concern. There are 17 data sets for the
value  of  NP  and  13  data  sets  are  in  the  proposed  BAT-AEL  range.  Emission  limit
values  for  this  parameter  are  set  in  some  national  regulations  (e.g.  in  France  0.025
mg/l and in Belgium 0.00008 mg/l) (AT 15).
  Set  a  BAT-AEL  range  for  DecaBDE  to  0.001-0.02  mg/l  because  DecaBDE  is  a
substance of environmental concern. In addition, there are 5 data sets for DecaBDE.
Finally, the use and production of the substance have been prohibited by the EU POP
Regulation 2019/1021 since 2019 (AT 17).
  Set  a  BAT-AEL  range  for  Sum  of  PFOA  and  PFOS  to  0.001-0.003  mg/l  because
PFOA and PFOS are substances of environmental concern. There are 8 data sets for
PFOA and 7 data sets for PFOS. In 2019, PFOA and its salts  were listed in category
A (Elimination) in the Stockholm Convention on Persistent Organic Pollutants (entry
into force: December 2020). In the EU, the production, placing on the market and use
of PFOA, its salts and polymers have been restricted in Annex XVII to REACH since
2017 (AT 19).

Adsorbable organically bound halogens (AOX)
  Increase  the  upper  end  of  BAT-AEL  range  for  polyester  and  blends  of
modacryl/cotton  to 1  mg/l, and change the BAT-AEL range for other  fibres  to 0.1-
0.6  mg/l.  Companies  with  specific  processes,  e.g.  polyester  dyeing  and
modacryl/cotton  dyeing,  have  an  AOX  discharge  of  1.9  mg/l  (90th    percentile)  and
1.46 mg/l (80th percentile) for indirect discharges. 1 mg/l is a reasonable limit based
on 10 times the environmental quality standard. A 90th percentile value for the upper
limit is more representative for the well-performing plants (EURATEX 21).
  Increase the upper end of the BAT-AEL range to 0.8 mg/l for dyeing products with
high lightfastness, and high quality demands (EURATEX 136).
  Lower the  upper end of the  BAT-AEL range to 0.3-0.4 mg/l. The upper  end of the
BAT-AEL range of 0.5 mg/l is in line with limits of certification schemes. Although
collected  data  indicate  that  many  plants  are  below  or  even  consistently  well  below
this  level,  contextual  information  (e.g.  on  the  set-up  and  process  conditions  of  the
waste  water  treatment  plants)  for  technically  deriving  a  more  ambitious  BAT  is
lacking (EEB 152, EEB 165).

Chemical oxygen demand (COD)
  Lower the upper end of  the BAT-AEL range to 100 mg/l because, according to the
collected data, the average concentration of only 3 plants is above 100 mg/l, there are
only 2 plants with a maximum concentration between 100 mg/l and 120 mg/l and 58
% of plants below 100 mg/l. With good physical, biological and chemical treatment,
less than 80 mg/l COD can be achieved (AT 3, SE 25).
  Decrease  the  BAT-AEL  range  to  30-100  mg/l  to  align  it  with  the  CWW  BAT
conclusions.  Collected  data  show  that  plants  achieve  concentrations  below  100 mg/l
and  those  above  120  mg/l  are  probably  not  applying  BAT.  Two  plants  achieve
concentrations  lower  than  the  proposed  BAT-AEL  range  (IT082  and  IT092),
indicating the best achievable level (EEB 153, EEB 165).
  Increase the upper end of the BAT-AEL range to 160 mg/l (FR_A 52).
  Increase the upper end of the BAT-AEL range to 160 mg/l because the 85th percentile
of  collected  data  represents  the  performance  of  the  majority  of  plants  better
(EURATEX 22, EURATEX 158).

Footnote (4)
  Decrease  the  upper  end  of  the  range  in  Footnote  (4)  to  130  mg/l  if  the  removal
efficiency  is  at  least  90 %.  Indeed,  the  exemption  should  be  rather  linked  to  the
removal efficiency because Table 5.1 (BAT-AEPLs for specific  water consumption)
shows  that  for  batch  processes  the  specific  water  consumption  ranges  are  above  25
m3/t  treated  textile  materials;  and  for  continuous  processes  below  25 m3/t  treated
textile materials. The strong variation of water consumption data shows that it is not
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appropriate  to  use  water  consumption  as  the  basis  for  an  exemption.  Also,  the
proposed threshold is hard for the authorities to control (AT 4).
  Increase  the  upper  end  of  the  BAT-AEL  range  in  Footnote  (4)  to  250 mg/l
(EURATEX 22,  EURATEX 158),  or  to  150 mg/l  (DE 272)  or  160 mg/l  (FR_A 52),
for waste waters with a high COD content in the influent if the removal efficiency of
the WWTP is at least 90 % (DE 272) or 95 % as a yearly or monthly average (e.g. see
FR131) (FR_A 52). Such a footnote was already added in the FDM BAT conclusions.
Define the high COD content in the influent (DE 272, FR_A 52).
  Increase  the  water  consumption  level  in  Footnote  (4)  to  the  one  reached  by  the
plants/sites  with  multiple  processes  and  process  routes;  according  to  the  data
collection,  only  a  few  single-process  sites  reach  the  proposed  level.  Add  in  the
footnote  the  expected  associated  BOD  level  equal  to  or  less  than  25 mg/l  as  an
indicator of the biodegradability of the effluent (UK 22).

Hydrocarbon oil index (HOI)
  Add  Footnote  (2)  to  this  parameter,  because  it  is  not  relevant  for  all  processes
(DE 370, CZ_B 7).
  Decrease the upper end of the BAT-AEL range to 5 mg/l. From the data collection,
there are 4 data sets for direct discharge applying biological treatment with activated
sludge achieving concentrations below 1 mg/l (AT 14).
  Keep or lower the upper end of the BAT-AEL (EEB 154, EEB 165).

Metals / metalloids
  Add  a  Footnote  (2)  to  these  parameters  as  they  are  not  relevant  for  all  processes
(DE 371).

Antimony (Sb)
  Increase the upper end of the BAT-AEL range for the cases where both processes are
applied in the plant (pretreatment and/or dyeing of polyester and finishing with flame
retardants using antimony  trioxide) to 0.6 mg/l. Increase the upper end of the BAT-
AEL  range  to  1.2  mg/l  for  plants  doing  polyester  and  modacryl/cotton  dyeing
(EURATEX 42).
  Increase the upper end of the BAT-AEL range for antimony to 0.5 mg/l. According to
Commission Implementing Decision 2012/119/EU (Section 3.3), rounded values can
be  set  as  BAT-AELs  to  take  into  account  limitations  in  the  data  collection  or  other
technical aspects (DE 366).
  Set  separate  BAT-AEL  ranges  for  each  process:  for  pretreatment  and  dyeing  the
upper  end  of  the  range  should  be  1.5  mg/l  (because  antimony  used  as  a  catalyst  for
polyester  production  is  leached  out  of  fibre  at  high  temperature  (above  softening
point)  and  emissions  cannot  be  avoided);  and  for  finishing  0.1-0.4  mg/l
(EURATEX 135) or 0.1-0.5 mg/l (DE 196) (emissions can be minimised by retention
of padding liquor and contaminated rinsing water) (EURATEX 135).
  Lower  the  upper end of the  BAT-AEL range  to 0.2 mg/l. Collected data  show that
around 65 % of the plants are below 0.2 mg/l. Experience from Austrian plants show
that lower values can be achieved by good chemical and water management (e.g. see
BAT  49).  Lower  values  can  be  achieved  with  abatement  techniques  nanofiltration,
microfiltration,  ultrafiltration,  prevention  measures  (separate  disposal  of  chemicals)
and precipitation. According to national waste  water legislation (AT Textile and AT
Glass),  0.3  mg/l  Sb  is  achieved  with  prevention  measures  (separate  disposal  of
chemicals) and precipitation (AT 46).
  Modify the BAT-AEL range  (both lower and upper ends)  to 0.01–0.15 mg/l. Three
out  of  four  installations  that  report  measurements  have  values  below  0.3 mg/l,  two
below  0.15  mg/l.  The  plant  with  the  lowest  emissions  has  substantial  activity  in
polyester dyeing.  ZDHC limits are 0.01 mg/l, 0.05 mg/l and 0.1 mg/l for their three
performance levels (EEB 155, EEB 165).

Chromium (Cr)
  Increase the lower end of the BAT-AEL range to 0.05 mg/l, because the lower limit
would  be  equal  to  environmental  quality  standards  (EQS)  in  the  Water  Framework
Directive. Treating waste water below EQS causes excessive costs (EURATEX 43).
  Increase the upper end of the BAT-AEL range for chromium to 0.5 mg/l. According
to  Commission  Implementing  Decision  2012/119/EU  (Section  3.3),  rounded  values
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can  be  set  as  BAT-AELs to  take  into  account  limitations  in  the  data  collection  or
other technical aspects (DE 366).
  Lower  the  upper  end  of  the  BAT-AEL  range  to  0.1  mg/l.  According  to  the  data
collected,  a  large  number  of  plants  can  easily  comply  with  0.1  mg/l.  The  data  sets
from Plants PT102, PT104, PT111 should not be included in the analysis because of
poor measurement quality (e.g. reporting results below the LoD, measuring the same
value repeatedly, etc.). Also, data sets from Plants IT063, IT072 and SE119 cannot be
considered BAT because of too high values (and fluctuations). Also, other standards
are  stricter  than  the  proposed  level:  e.g.  ZDHC  requires  0.05/0.1/0.2  mg/l  as
maximum  levels  for  the  three  performance  classes;  and  Oeko-tex  requires  0.2  mg/l
(EEB 156, EEB 165).

Copper (Cu)
  Increase the lower end of the BAT-AEL range to 0.05 mg/l, because the lower limit
would  be  equal  to  environmental  quality  standards  (EQS)  in  the  Water  Framework
Directive. Treating waste water below EQS causes excessive costs (EURATEX 43).
  Increase the upper end of the BAT-AEL range for copper to 0.5 mg/l. According to
Commission Implementing Decision 2012/119/EU (Section 3.3), rounded values can
be  set  as  BAT-AELs to  take  into  account  limitations  in  the  data  collection  or  other
technical aspects (DE 366).
  Increase the upper end of the BAT-AEL range to 0.8 mg/l for dyeing products with
high lightfastness, and high quality demands (EURATEX 137).
  Lower the upper end of BAT-AEL range to 0.2 mg/l. Add a footnote that in the case
of increased lightfastness requirements (use of copper-containing dyes), the upper end
of  the  BAT-AEL  range  is  up  to  0.4  mg/l.  According  to  the  collected  data,  around
65 %  of  the  plants  are  below  0.2  mg/l.  Abatement  technologies  reverse  osmosis,
nanofiltration, microfiltration could be used (AT 7).
  Lower  the  upper  end  of  the  BAT-AEL  range  to  0.2  mg/l.  According  to  the  data
collection, reported values are generally well below 0.2 mg/l (EEB 157, EEB 165).

Nickel (Ni)
  Increase the lower end of the BAT-AEL range to 0.05 mg/l, because the lower limit
would  be  equal  to  environmental  quality  standards  (EQS)  in  the  Water  Framework
Directive. Treating waste water below EQS causes excessive costs. (EURATEX 43).
  Increase the upper end of the BAT-AEL range for nickel to 0.5 mg/l. According to
Commission Implementing Decision 2012/119/EU (Section 3.3), rounded values can
be  set  as  BAT-AELs to  take  into  account  limitations  in  the  data  collection  or  other
technical aspects. (DE 366).
  Lower  the  upper  end  of  the  BAT-AEL  range  to  0.08  mg/l  and  add  a  footnote
mentioning  that  the  upper  end  corresponds  to  the  use  of  nickel-containing  dyes.
Indeed,  according  to  the  collected  data,  around  70 %  of  the  plants  are  below
0.08 mg/l.  In  addition,  nickel  is  a  Priority  Substance.  Finally,  experience  from
Austrian  plants  shows  that  0.08  mg/l  can  be  achieved  by  good  chemical  and  water
management  (see  BAT  39-42).  The  plants  with  emission  values  > 0.05 mg/l  do  not
use abatement technologies such as reverse osmosis, ultrafiltration or microfiltration
(except Plant IT092_w(1)) (AT 9).
  Change  the  BAT-AEL  range  to  0.005-0.05  mg/l  to  align  it  with  the  CWW  BAT
conclusions. According to the data collected, reported values are well below 0.4 mg/l,
in most cases even below 0.05 mg/l. The higher reported values show very high error
bars  and  should  not  be  included  in  the  analysis  (poor  process  control,  few
measurements,  poor  measurement  quality,  erroneous  measurement  or  sampling,
malfunction  of  the  water  treatment  facility).  Oekotex  and  ZDHC  require  maximum
emission levels of 0.2 mg/l (EEB 158, EEB 165).

Zinc (Zn)
  Increase the upper end of the BAT-AEL range to 2 mg/l. The source of Zn emissions
is corrosion of pipes (DE 367, EURATEX 157).
  Increase the lower end of the BAT-AEL range to 0.2 mg/l, because the lower limit
would  be  equal  to  environmental  quality  standards  (EQS)  in  the  Water  Framework
Directive. Treating waste water below EQS causes excessive costs (EURATEX 43).
  Lower the lower end of the range to 0.02 mg/l (EEB 165). Lower the upper end of the
BAT-AEL range to 0.3 mg/l to align it with the CWW BAT  conclusions. According
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to  the  data  collected,  few  data  points  are  between  0.3 mg/l  and  0.5  mg/l  (EEB 159,
EEB 165).

Sulphide, easily released (S2-)
  Change the BAT-AEL range to 0.1-0.5 mg/l. According to the data collected, plants
achieve  lower  values.  There  is  only  one  plant  (direct  discharge)  over  0.5 mg/l
(AT 11).
  Change the BAT-AEL range to 0.05-0.2 mg/l. According to the data collected, a lot
of measurements are reported at  the limit of detection. The ZDHC standard requires
0.01/0.05/0.5 mg/l for their three levels (EEB 160, EEB 165).

Total nitrogen (TN)
  Lower  the  upper  end  of  the  BAT-AEL  to  10 mg/l  (EEB 161,  EEB 165)  or  15 mg/l
(SE 28).  This  would  align  the  upper  end  of  the  BAT-AEL  with  an  ecosystem-
dependent condition as in the Directive on urban waste water treatment (91/271/EC).
According  to  the  data  collected,  the  upper  end  could  be  lowered  (SE 28,  EEB 161,
EEB 165).

Footnote (5)
  Set an upper end of the BAT-AEL range for cold conditions.(EEB 187).
  Specify  “prolonged”  in Footnote  (5), because  on an average  day  the  temperature  of
20 % of the waste water collected over one day is equal to or below 12 °C (AT 41).

Total organic carbon (TOC)
  Change the BAT-AEL range to 10-30 mg/l. The collected data for TOC show lower
values and only a few plants are above 30 mg/l (AT 5).
  Lower the upper end of the BAT-AEL range to 30 mg/l, because this is supported by
the data collection (SE 28).
  Keep the BAT-AEL range as proposed (EEB 162, EEB 165).

Footnote (6)
  Modify the footnote allowing a higher upper end of the BAT-AEL for TOC up to 50
mg/l  for  waste  waters  with  a  high  TOC  content  in  the  influent  if  the  removal
efficiency of the WWTP is at least 90 %. Define the high TOC content in the influent
(DE 369).
  Decrease  the  upper  end  of  the  range  in  Footnote  (6)  to  40  mg/l  if  the  removal
efficiency  is  at  least  90 %.  Indeed,  exemption  should  rather  be  linked  to  removal
efficiency  because  Table  5.1  (BAT-AEPLs  for  specific  water  consumption)  shows
that  for  batch  processes  the  specific  water  consumption  ranges  are  above  25  m3/t
treated  textile  materials;  and  for  continuous  processes  below  25  m3/t  treated  textile
materials.  The  strong  variation  of  water  consumption  data  shows  that  it  is  not
appropriate  to  use  water  consumption  as  the  basis  for  an  exemption.  Also,  the
proposed threshold is hard for the authorities to control (AT 6).

Total phosphorus (TP)
  Lower the upper end of the BAT-AEL range to 2 mg/l. Only data sets for plants with
direct  discharge  using  BATs  for  phosphorus  removal  should  be  used  for  setting  a
BAT-AEL (BE 22, DE 368).
  Increase  the  upper-end of the BAT AEL range  to 10  mg/l. Add another BAT-AEL
range for flame-retardant treatments using phosphorus compounds (FR_B 8).
  Do  not  consider  organophosphates  when  evaluating  Total  phosphorus.
Organophosphorus  flame  retardants  are  persistent  but  not  bioaccumulative  or  toxic.
This  organic  phosphorus  does  not  contribute  to  the  eutrophication  of  surface  water.
Actions  regarding  pad  liquors  and  highly  concentrated  rinsing  water  are  taken  by
plants to avoid excess of discharge (EURATEX 44).
  Modify the BAT-AEL range  to 0.01-2 mg/l. The collected data show lower values.
Total  phosphorus  is  easy  to  precipitate.  Such  an  upper  end  of  the  BAT-AEL  range
was set in the FDM BAT conclusions (AT 13).
  Modify  the  BAT-AEL  range  to  0.1-3  mg/l  and  add  a  footnote  that  for  the  plants
discharging into eutrophication-sensitive areas the upper end of the range is 1 mg/l or
2 mg/l (depending on size) as set by the UWWTD. Finally, the certification scheme
ZDHC  as  well  as  the  CWW  BAT  conclusions  have  emission  limit  values  at  3  mg/l
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(EEB 163,  EEB 165).  Lower  the  upper  end  of  the  BAT-AEL  range  to  2  mg/l.
According  to  the  data  collected  and  the  UWWTD,  the  upper  end  could  be  lowered
(SE 28).

Total suspended solids (TSS)
  Lower  the  upper  end  of  the  BAT-AEL  range  to  35  mg/l  to  align  with  the  CWW
BREF.  These  solids  can  have  metals  and  metalloids  associated  with  them  and  can
therefore  pose  a  significant  threat  to  downstream  ecology  (EEB 164,  EEB 165,
UK 23).
  Lower  the  upper  end  of  the  BAT-AEL  range  to  35  mg/l.  According  to  the  data
collected and the UWWTD, the upper end could be lowered (SE 28).

General comments
  To derive the BAT-AELs for direct discharges, the data reported for direct discharges
have been taken into consideration. However, in the case of sulphides and metals, the
indirect  discharges  were  additionally  considered  to  confirm  the  assessment.  For
details, see the corresponding assessments for parameters below.
  According to Section 8.1.1 of the KoM conclusions, the BAT-AELs for emissions to
water are expressed in concentrations, and not in loads.
  The proposed BAT-AELs are based on the emission data sets related to the treatment
techniques  applied  by  the  different  TXT  installations.  Additional  contextual
information  like  use  of  raw  materials,  processes,  chemicals  and  auxiliaries  used  are
taken into consideration.
  Furthermore, a  2nd Data Assessment Workshop  was organised in October 2020,  in
order  to  clarify  the  approach  used  by  the  EIPPCB  to  derive  the  BAT-AE(P)Ls
proposed  in  D1,  and  to  discuss  the  data  situation  in  relation  to  the  BAT-AE(P)Ls
proposed in D1.
  The comments from that workshop and additional information provided after it have
been  taken  into  account  to  formulate  the  EIPPCB  assessments  and  proposals  in  this
background paper.

Additional parameters
  According to the KoM conclusions, the data on BODn emissions were to be collected
as  contextual  information,  but  it  was  decided  not  to  propose  a  BAT-AEL  for  this
parameter.  However,  BODn  indicative  emission  levels  related  to  COD/TOC  BAT-
AELs could be set (e.g. in a footnote to the table) to indicate the abatement efficiency
EIPPCB
of the well-performing biological waste water treatment (e.g. also for checking  non-
assessment:
biodegradability of effluent with BOD to COD ratio).
  According to the KoM conclusions, data were to be collected for the TWG to decide
at  a  later  stage,  based  on  their  availability  and  comparability,  to  potentially  set  a
BAT-AEL for colour. In the data collection, 35 data sets (from 16 emission points, 6
direct / 10 indirect discharge)  were reported for colour, 3 reported in units of Pt-Co
scale, 10 in SAC (m-1), 3 in mg/l Pt and 19 reported measurements or ELVs but no
unit (of these, 16 seem to be reporting a dilution factor of 1:20). Data obtained with
different  methods do not seem to be comparable.  The colour parameter seems to be
qualitative  and  operational  parameter  that  is  measured  (e.g.  daily)  to  control  the
operation  of  waste  water  treatment.  Similarly  to  biodegradability  or  toxicity  for
example,  the  requirements  for  monitoring  of  this  parameter  are  set  in  BAT 7;
however, setting a BAT-AEL does not seem to be necessary or practical.
  According  to  the  KoM  conclusions,  the  data  on  Total  N  emissions  were  to  be
collected  to  set  a  BAT-AEL.  Ammonium  nitrogen  (NH4-N)  was  considered  to  be
included  in  the  Total  N.  In  accordance  with  the  practice  of  the  recent  BAT
conclusions, BAT-AELs and monitoring for total nitrogen (TN) are proposed, as this
parameter better reflects the eutrophication potential.
  According to the KoM conclusions, data were to be collected for the TWG to decide
at  a  later  stage,  based  on  their  availability  and  comparability,  to  potentially  set  a
BAT-AEL for toxicity. As presented in  Section 3.4.18 of D1 of  the TXT BREF, the
availability  and  comparability  of  data  was  insufficient  to  set  a  BAT-AEL  for  this
parameter.
  Regarding  nonylphenol,  8  out  of  15  emission  points  to  water  reported  using  the
standard  method  for  nonylphenol.  Except  BE014_{1}  who  reported  WAC/IV/A/01-
05,  UNI  EN  ISO  18857  is  the  standard  method  reported  for  the  other  7  emission
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points to water.
o  Of  those  emission  points  that  reported  using  the  standard  method  for
nonylphenol,  4  emission  points  to  water  (i.e.  IT064_{1},  IT071_{1},
IT089_{1}  and  IT090_{1})  reported  the  same  concentration  value  of
0.2 µg/l,  while  the  maximum  concentration  range  obtained  for  the  other  4
emission points to water goes from 1.3 µg/l to 20 µg/l.
o  The working range  set  for nonylphenol in UNI EN ISO 18857-2 is 0.5 µg/l
to 50 µg/l.
  Taking into account the above information, it seems there are not enough comparable
data available to set a BAT-AEL for nonylphenol of 0.2-5 µg/l.
  Regarding DecaBDE, 5 emission points to water reported measured values. 2 out of 5
provide  information  about  the  standard  method  used  (i.e.  AT004_{1}  and
BE011_{1}).
o  AT004_{1}  reported  EPA 8270  and  BE011_{1}  reported  WAC/IV/A/030.
Both methods use Gas Chromatography/Mass Spectrometry (GC-MS).
o  AT004_{1} reported 5 measurements, all carried out in 2015 within a range
from 0.46 µg/l to 52 µg/l, while BE011_{1} reported one measurement done
in 2017 of 0.18 µg/l.
  Taking into account the above information, it seems there are not enough comparable
data available to set a BAT-AEL for DecaBDE of 1-20 µg/l.
  Regarding the BAT-AEL range for the sum of PFOA and PFOS, taking into account
the data collection, 10 emission points to water reported measured values for PFOA,
6  emission  points  to  water  reported  measured  values  for  PFOS,  and  DE031_{1}
reported measured values for PFOS:PFOA.
o  4 out of 10 emission points to water reported the standard method used for
PFOA.  BE011_{1}  and  BE014_{1}  use  Liquid  Chromatography  with
tandem  mass  spectrometry  (LC-MS-MS);  IT092_{1}  and  IT097_{1}
reported MI1207 rev2:2018. The range  of the maximum values reported by
the 4 emission points to water mentioned goes from 13 µg/l to 41 µg/l.
o  1  out  of  6  emission  points  to  water  reported  the  standard  method  used  for
PFOS.  BE014_{1}  uses  Liquid  Chromatography  with  tandem  mass
spectrometry  (LC-MS-MS),  and  reported  1  measurement,  done  in  2016,  of
0.5 µg/l.
  Taking into account the above information, it seems there are not enough comparable
data available to set a BAT-AEL for the sum of PFOA and PFOS of 1-3 µg/l.

Adsorbable organically bound halogens (AOX)
  The statistical approach (percentiles) or environmental quality standards are not used
to derive BAT-AELs.
  Regarding the proposals to increase the upper end of the BAT-AEL range:
o  Due  to  dyeing  of  polyester  and  blends  of  modacryl/cotton,  the  relevant
emission  points  for  direct  discharge  are  CZ020_{1},  BE014_{2},
DE025_{1}, FR131_{2} and FR134_{1}. It is not clear how the upper end
could  be  raised  to  1  mg/l,  since  the  highest  reported  value  is  0.86  mg/l
(FR134_{1}).
o  If dyeing with vat, metal-complex and reactive dyes is assumed to represent
the  category  of  ‘dyeing  products  with  high  lightfastness,  and  high  quality
demands’,  the  emission  points  for  direct  discharge  reporting  dyeing  with
these  dyes  are  BE011_{1},  FR131_{1}  and  FR134_{1},  with  maximum
concentrations  of  0.38 mg/l,  0.41 mg/l  and  0.86 mg/l.  The  average
concentration  for  the  one  reporting  the  highest  value  (FR134_{1})  is
0.3 mg/l;  therefore,  it  seems  that  the  proposed  upper  end  of  the  range  is
mostly respected by all relevant plants.
  Regarding the proposals to lower the upper end of the BAT-AEL range:
o
The BAT-AELs are not derived on the basis of certification schemes.
o
The  collected  data  for  direct  discharges  in  some  cases  indicate  high
fluctuations  in  AOX  concentrations.  Minimal,  average  and  maximal
concentrations  for  BE011_{1}  are  0.08  mg/l,  0.17 mg/l  and  0.38  mg/l,  for
FR131_{1}  0.02 mg/l,  0.13 mg/l  and  0.41  mg/l,  for  FR132_{2}  0.02 mg/l,
0.2 mg/l  and  0.66  mg/l,  and  for  FR134_{1}  0.06 mg/l,  0.3 mg/l  and
0.86 mg/l.  All  plants  use  activated  sludge,  but  only  BE011  also  uses  sand
filtration,  chemical  oxidation  and  coagulation/flocculation  which  would
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remove  AOX.  These  fluctuations  seem  to  be  limited  to  only  a  few
measurements/events,  with  the  majority  being  well  below  0.4 mg/l.
Therefore, the upper end of the range for direct discharge could be decreased
to 0.4 mg/l.

Chemical oxygen demand (COD)
  Two  emission  points  to  water  reported  maximum  concentration  values  between
100 mg/l and 120 mg/l, i.e. IT067_{1} and FR132_{2}:
o  IT067_{1}  monitored  COD  with  a  monthly  frequency  and  reported  37
values  over  3  years  with  a  range  of  24 mg/l  to  108  mg/l.  The  maximum
value reported is 108 mg/l, slightly above 100 mg/l.
o  FR132_{2} monitored COD with a daily frequency and reported 12 values
for  2016  in  the  range  52 mg/l  to  105  mg/l,  and  12  values  for  2017  in  the
range 97 mg/l to 115 mg/l.
  Taking into account the values reported by IT067_{1} and FR132_{2}, there is scope
for lowering the upper end of the BAT-AEL range.
  BAT-AELs  set  in  the  CWW  BAT  conclusions  for  COD  refer  to  a  yearly  average,
while in TXT D1 the proposed BAT-AELs refer to daily average values, in the case
of  continuous  discharge,  or,  in  the  case  of  batch  discharge,  average  values  over  the
release duration taken as  flow-proportional composite samples, or, provided that the
effluent  is  appropriately  mixed  and  homogeneous,  a  spot  sample  taken  before
discharge, as described in the definition of BAT-AELs for emissions to water in the
General considerations section of the BAT conclusions. Both values are therefore not
directly comparable.
  Furthermore,  to  decrease  the  lower  end  of  the  range  to  30  mg/l,  there  are  no  data
reported in the data collection  with a maximum concentration value for COD below
30 mg/l.
  The BAT-AELs are not derived using a statistical approach. The fact that 5 out of 24
of  the  emission  points  to  water  reported  a  maximum  emission  level  higher  than  the
proposed higher end of the BAT-AEL range is not per se a reason for increasing the
higher end of the range. Technical reasons explaining why the proposed upper end of
the BAT-AEL range could not be achieved are not provided.

Footnote (4)
  In  the  data  collection,  only  one  emission  point  to  water,  CZ020)_w{1},  reported
information about the removal efficiency for COD direct discharge. The COD content
in  the  influent  for  CZ020)_w{1}  is  around  127 mg/l,  obtained  by  the  calculation
using the maximum concentration value for COD reported (65 mg/l), and the removal
efficiency (95 %).
  After  the  2nd  Data  Assessment  Workshop  held  on  21-23  October  2020,  more
information  about  the  removal  efficiency  was  provided  by  EURATEX,  France  and
Sweden:
o  EURATEX  provided  information  for  three  Belgian  plants,  two  of  them
participated in the data collection (i.e. BE009 and BE010) and the third one
was not included in the data collection for the TXT BREF review,
o  In the case of BE009, the range of the reported values were for COD influent
from 393 mg/l to 1870 mg/l and for COD effluent from 50 mg/l to 353 mg/l,
with  a  removal  efficiency  ranging  from  55 %  to  96  %.  In  the  case  of  a
removal  efficiency  equal  to  or  higher  than  90%,  the  highest  COD
concentration reported is 124 mg/l.
o  In the case of BE010, the range of the reported values were for COD influent
from 351 mg/l to 1600 mg/l and for COD effluent from 31 mg/l to 128 mg/l,
with  a  removal  efficiency  ranging  from  79 %  to  96  %.  In  the  case  of  a
removal  efficiency  equal  to  or  higher  than  90 %,  the  highest  COD
concentration reported is 110 mg/l.
o  In the case of the third plant which did not participate in the data collection,
the  values  reported  were:  COD  influent  1200 mg/l  and  COD  effluent
49 mg/l, with a removal efficiency of 96 %.
o  France  provided  information  about  the  daily  removal  efficiency  for  the
emission  point  FR131_w{1}  for  a  complete  year  from  December  2019  to
November  2020.  The  average  value  reported  for  COD  influent  was
3811 mg/l  and  for  COD  effluent  122 mg/l,  with  a  removal  efficiency  of  97
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%.
o  Sweden provided information about the COD removal efficiency achieved in
the  waste  water treatment plant called Skene. This plant received the  waste
water  discharge  from  four  textile-dyeing  installations.  The  COD  removal
efficiency reported is in the range of 90-95 %.
  Taking into account the above information about removal efficiency, it is not possible
to  propose  a  footnote  based  on  removal  efficiency  to  increase  the  upper  end  of  the
BAT-AEL range up to 150 mg/l, 160 mg/l or 250 mg/l, as in the information provided
for  CZ020)_w{1},  BE010  and  FR131_w{1}  the  COD  effluent  concentration
corresponding to a removal efficiency of at least 90 % is below 150 mg/l.
  Footnote  (4)  refers  to  specific  waste  water  discharged,  not  to  specific  waste  water
consumption. This can be further clarified in the footnote.
  Biodegradability of waste water is addressed in BAT 18. It does not appear necessary
to repeat it in Table 5.3.

Hydrocarbon oil index (HOI)
  It  is  considered  appropriate  to  add  Footnote  (2),  as  oils  in  waste  water  may  not
originate from all processes (i.e. typically from washing synthetic fibres and knitting)
or fibres (i.e. typically from synthetic fibres and knitted fabrics).
  Only  three  emission  points  (IT092_{1},  IT097_{1}  and  BE007_{1})  reported
concentration  values  of  HOI  for  direct  discharges,  with  a  range  from  0.03 mg/l  to
0.93  mg/l.  The  associated  processes  of  these  emission  points  do  not  seem  typical
sources  of  emissions  of  oils.  However,  oils  may  enter  the  processes  (and  effluents)
with  incoming  textile  materials  (e.g.  for  these  three  plants:  polyamide  or  polyester
fibres,  knitted  fabrics).  All  three  plants  use  an  appropriate combination  of  treatment
techniques  (e.g.  neutralisation,  equalisation,  activated  sludge  and  sedimentation);
furthermore,  two  plants  also  use  techniques  that  would  effectively  remove  oils  (i.e.
sand filtration (BE007) and reverse osmosis (IT092)).
  Based on these three data sets, less than 1 mg/l seems to be an appropriate BAT-AEL.
However,  it  seems  more  representative  (due  to  more  typical  processes,  sources  and
materials  related  to  oil  emissions)  to  also  include  in  the  BAT-AEL  derivation  data
reported  for  indirect  discharges  (e.g.  30  data  sets),  especially  if  the  plants  use
appropriate abatement techniques. For example, taking data from these three data sets
into  account  would  support  decreasing  the  upper  end  of  the  BAT-AEL  range  for
direct and indirect discharge to 7 mg/l: PT108_{1} (maximum concentration 4 mg/l;
fabric  production  processes  and  knitted  fabrics;  using  sand  filtration),  PT104_{1}
(average/maximum concentrations 2.5 mg/l/7 mg/l; knitted fabrics, ultrafiltration) and
PT114_{1}  (average/maximum  concentrations  6.7 mg/l/10 mg/l;  washing  synthetic
fibre, adsorption, sedimentation, sand filtration). .

Metals / metalloids
  It is considered appropriate and consistent with BAT 2 and BAT 7 to add Footnote (2)
to metals for which any specific process is mentioned.

Antimony (Sb)
  BAT-AELs  are  not  derived  based  on  a  statistical  approach,  and,  despite  rounded
values  having  already  been  set  as  BAT-AELs  according  to  Commission
Implementing  Decision  2012/119/EU,  it  is  not  clear  on  which  reported  data  the
rounded value would be based.
  Regarding the comments received for increasing/lowering the range:
o  For  direct  emissions:  IT097_{1}  reported  two  values  (only  in  2018),
0.01 mg/l and 0.5 mg/l  (which is in fact the detection limit of the monitoring
method  referred  to).  All  of  the  other  five  EPs  reported  values  <  0.2  mg/l,
whatever the process or the type of textile fibre used.
o  For indirect emissions: three EPs reported values higher than the upper end
of the range of the BAT-AEL proposal in D1: DE051_{1}, DE022_{1} and
SE120_{1}:
  SE120_{1} reported the highest value, 1.1 mg/l, and the monitoring
is based on a continuous flow-proportional sampling and the value
represents  a  whole  month  and  is  used  together  with  the  flow  to
calculate  the  emissions  in  kg/year,  so  this  is  not  directly
comparable.
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  DE022_{1}:  the  monitoring  frequency  is  monthly  and  this  EP
reported  a  value  above  the  BAT-AEL  proposal  once,  0.7  mg/l  in
2016,  while  the  emission  limit  value  prescribed  by  the  competent
authority in the permit is 0.4 mg/l.
  DE051_{1}:  the  monitoring  frequency  is  monthly  and  this  EP
reported  a  value  above  the  BAT-AEL  proposal  once,  0.44 mg/l  in
2016.
  In  addition  to  the  EPs  mentioned  above,  SE119_{1}  reported  a
value of 0.35 mg/l in 2018 and is not using abatement technique.
  Based on this analysis for both direct and indirect emissions, there is scope to lower
the upper end of the BAT-AEL range for both direct and indirect emissions.

Chromium (Cr)
  BAT-AELs are derived from the data collection; they are not based on environmental
quality standards referring to the quality of water.
  It is not technically clear why it is necessary to set rounded values for increasing the
upper end of the BAT-AEL range.
  Regarding the proposal for lowering the upper end of the range, the assessment has
been done for both direct and indirect emissions:
o  Among the plants that have reported direct emissions of chromium to water,
there  are  6  emission  points  to  water  with  maximum  values  higher  than
0.1 mg/l:  PT111_{1},    PT098_{1},  IT067_{1},  BE007_{1},  BE009_{1}
and  BE014_{1}.  Taking  into  account  the  values  based  on  a  standard
monitoring  method  and  considering  the  number  of  values  reported  above
0.1 mg/l  versus  the  number  of  all  the  values  reported  by  each  EP,  the
majority of the values are below 0.1 mg/l.
o  Regarding  indirect  emissions,  IT84_{1}  is  applying  coagulation,
flocculation  and  sedimentation  and  once  reported  0.13  mg/l  while  the  11
other  values  are  below  0.03  mg/l.  All  the  other  emission  points  reporting
values higher than 0.1 mg/l are not using a relevant abatement technique.
o  According to the above data points, there is scope to lower the upper end of
BAT-AEL range.

Copper (Cu)
  BAT-AELs are derived from the data collection; they are not based on environmental
quality standards referring to the quality of water.
  Despite  rounded  values  having  already  been  set  as  BAT-AELs  according  to
Commission Implementing  Decision 2012/119/EU, it is not clear on  which reported
data the rounded value would be based.
  As similar comments have been received for both direct and indirect emissions,  the
assessment  is  presented  in  this  section.  According  to  Section  2.7.2  of  D1,  high
lightfastness  is  ensured  by  the  use  of  vat  dyes  or  metal-complex  dyes.  In  addition,
according to Section 3.4.9.2 of D1, reactive dyes may contain copper too. This could
be reflected in the processes/activities concerned.
  Regarding the comments received to increase the upper end of the range:
o  Plants  using  vat  dyes  reported  data  from  0.02  mg/l  to  0.79  mg/l.
IT071_w{2}  and  IT072_w{1}  reported  values  higher  than  the  BAT-AEL
proposal  in  D1  but  they  are  not  applying  any  technique  to  reduce  the  Cu
concentration.
o  6  plants  using  metal-complex  dyes  reported  values  higher  than  the  BAT-
AEL  proposal  in  D1  but  they  are  not  applying  any  technique  to  reduce  the
Cu concentration.
o  Among  the  75  plants  that  have  reported  Cu  emissions  and  using  reactive
dyes, 8 reported values higher than the BAT-AEL proposal in D1. 7 are not
applying any technique to reduce the Cu concentration. SE120_{1} reported
the  highest  value,  1.5  mg/l,  and  is  not  using  techniques  such  as  reverse
osmosis, nanofiltration or microfiltration.
o  Based on this information, there is no scope to increase the upper end of the
BAT-AEL range.
  Regarding the comments received to decrease the upper end of the range, the BAT-
AELs  are  not  derived  on  the  basis  of  a  statistical  approach  and  it  is  not  technically
clear why it is necessary to add a footnote for plants using the dyes listed above and
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that have reported values lower than 0.4 mg/l.

Nickel (Ni)
  BAT-AELs are derived from the data collection; they are not based on environmental
quality standards referring to the quality of water.
  Despite  rounded  values  having  already  been  set  as  BAT  AELs  according  to
Commission  Implementing Decision 2012/119/EU, it is not clear on  which reported
data the rounded value would be based.
  As similar comments have been received for both direct and indirect emissions, the
assessment  is  presented  in  this  section.  Regarding  the  comments  received  for
lowering the upper end of the range, 13 EPs reported values higher than 0.09 mg/l, for
both direct and indirect emissions of Ni:
o  3  EPs  are  not  using  any  techniques:  IT071_w{1},  PT105_w{1}  and
PT102_w{1}. PT113_w{1} implements only a screening technique.
o  PT111_w{1}  reported  a  yearly  value,  0.5  mg/l  without  referring  to  a
standard monitoring method twice, and then reported 0.01 mg/l referring to a
standard monitoring method.
o  FR134_w{1} monitored Ni 4 times a year and reported 0.19 mg/l once while
3 other values are below 0.083 mg/l and 8 values below 0.01 mg/l.
o  In IT092_w{1} Ni is monitored monthly, the highest value (1 mg/l) has been
reported once but all the other values are below 0.1 mg/l.
o  BE009_w{1} reported 0.09 mg/l as the highest value, and both IT092_w{1}
and BE009_w{1} use reverse osmosis.
o  All the other EPs use techniques that are not relevant for the abatement of Ni
emissions.
o  According  to  the  above  points,  there  is  scope  to  lower  the  upper  end  of
BAT-AEL range.
  According to Section 3.4.9.3 of D1, reactive dyes may contain metals such as nickel,
and this could be reflected in the processes/activities concerned. It is not clear why it
is necessary to add a footnote corresponding to the use of nickel-containing dyes, as
most  of  the  plants  that  have  reported  data  on  nickel  emissions  and  implementing
reactive dying achieve below 0.08 mg/l.
  As described in the  definition of BAT-AELs  for emissions to  water  in the General
considerations  section  of  the  BAT  conclusions,  BAT-AELs  set  in  the  CWW  BAT
conclusions for nickel refer to a yearly average, while in TXT D1 the proposed BAT-
AELs refer to:
o  daily average values in the case of continuous discharge;
o  average  values  over  the  release  duration  taken  as  flow-proportional
composite  samples,  or  a  spot  sample  taken  before  discharge  (provided  that
the effluent is appropriately  mixed and  homogeneous), in  the case of batch
discharge.
Both values (CWW and TXT) are therefore not directly comparable.

Zinc (Zn)
  BAT-AELs are derived from the data collection; they are not based on environmental
quality standards referring to the quality of water.
  Regarding  the  comment  received  on  increasing  the  upper  end  of  the  range,  the
assessment  has been done considering both direct and indirect  discharges. Based on
the inputs following the 2nd data workshop, it has not been confirmed that pipes are a
source  of  zinc  emissions  to  water.  Instead,  several  sources  of  zinc  emissions  have
been  mentioned,  e.g.  yarns  of  mass-coloured  acrylic  fibres,  use  of  cationic  dyes,
bleaching  with  the  dithionite  process,  and  cellulose  fibres  (regenerated  cellulose
fibres, and zinc salts used in the production process).
o  The maximum reported concentration of zinc for direct emissions to water is
0.5 mg/l whatever the process.
o  Regarding  data  reported  for  indirect  emissions:  29  EPs  reported  values
higher than the upper end of the BAT-AEL range proposed in D1, including
18  EPs  not  using  any  techniques  to  reduce  water  pollution.  Among  the  11
remaining EPs and comparing the processes and types of fibres used:
  DE042_w{1}  and  IT087_w{1}  both  report  batch  cationic  dyeing
and  are  applying  only  equalisation  (while  all  EPs  reporting  values
for  direct  emissions  are  compliant  with  the  BAT-AEL  range
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proposal);
  SE120_w{1} is the only EP reporting bleaching with the dithionite
process, and reported 1.7 mg/l for Zn emissions while the Emission
Limit Value is 0.5 mg/l;
  IT087_w{1}  reported  a  value  of  0.7  mg/l  and  the  use  of  viscose
(while PT098_w{1} reported values for direct emissions compliant
with the BAT-AEL range proposal).
o  It is therefore not clear why the upper end of the BAT-AEL range should be
increased to 2 mg/l.
  As described in the  definition of BAT-AELs  for emissions to  water  in the General
considerations  section  of  the  BAT  conclusions,  BAT-AELs  set  in  the  CWW  BAT
conclusions for zinc refer to a yearly average, while in TXT D1 the proposed BAT-
AELs refer to:
o  daily average values in the case of continuous discharge;
o  average  values  over  the  release  duration  taken  as  flow-proportional
composite  samples,  or  a  spot  sample  taken  before  discharge  (provided  that
the effluent is appropriately  mixed and  homogeneous), in  the case of batch
discharge.
o  Both values (CWW and TXT) are therefore not directly comparable.

Sulphide, easily released (S2-)
  According  to  the  data  collection,  3  emission  points  to  water  reported  values  for
sulphide  for  direct  discharge  (i.e.  IT067_{1},  IT092_{1}  and  IT097_{1}).  The
concentration  values  reported  by  these  emission  points  were  close  to  or  below  the
detection  limit.  Maybe  these  plants  are  not  using  sulphur  dyes.  In  that  case,  the
concentration values reported for indirect discharges were additionally considered to
confirm the proposed higher end of the BAT-AEL range.
  Regarding the lower end of the range, there are not emission points to water reporting
a value of 0.3 mg/l in the data collection, while there are 7 emission points to water
(e.g. ES058_{1}, DE024_{1}, IT067_{1}) achieving lower concentration values than
0.3 mg/l  and  using  similar  techniques  to  those  reported  for  other  emission  points.
According to these values, there is scope for lowering the upper end of the BAT-AEL
range.
  BAT-AELs are set based on emission data collected through the questionnaires from
the plants using BAT. BAT-AELs are not based on other standards (e.g. ZDHC).

Total nitrogen (TN)
  There  are  three  emission  points  to  water  (IT092_w{1},  IT097_w{1}  and
BE010_w{1}),  using  nitrification/denitrification  treatment,  with  reported  maximum
values between 10 mg/l and 20 mg/l:
o  IT092_w{1}  reported  one  concentration  value  for  TN  (17.1  mg/l),  while
IT097_w{1} reported two values, 6.0 mg/l and 18.5 mg/l.
o  BE010_w{1}  reported  a  minimum  of  four  concentration  values  per  year,
giving more representativeness to the data series reported. Figure 3.28 in D1
shows that the difference between its maximum and average concentration is
more than double.
  According to the above points, and looking in detail at all the reported concentration
values  and  using  nitrification/denitrification  treatment,  there  is  scope  to  lower  the
upper end of BAT-AEL range.

Footnote (5)
  There is only one data set for direct discharge, using nitrification/denitrification and
an  appropriate  monitoring  standard,  that  reported  the  effluent  temperature  data
(BE014).  This  does  not  seem  a  broad  basis  to  set  the  upper  end  of  the  BAT-AEL
proposal for cold conditions.
  It seems better for implementation not to specify what is meant by “prolonged” due to
possible different approaches originating from local climatological and environmental
conditions, which are best captured by the competent authority. Additionally, the data
collection was not designed to provide any information on this issue.

Total organic carbon (TOC)
  A total of 2 out of 9 emission points to water reported maximum concentration values
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between 30 mg/l and 40 mg/l, i.e. BE014_w{1} and BE007_w{1}:
o  BE014_w{1} reported 4 measurements, all done during the year 2018. The
range  of  the  values  was  from  20 mg/l  to  31 mg/l.  For  the  same  year,  the
concentration of COD ranges from 44 mg/l to 74 mg/l, below the proposed
BAT-AEL for COD.
o  BE007_w{1}  reported  12  measurements  for  2016,  with  two  measurements
above 30 mg/l (i.e. 32 mg/l and 35 mg/l), and an average value of 24 mg/l in
2016.  11  measurements  were  reported  in  2017,  with  one  value  above
30 mg/l  (i.e.  35  mg/l),  and  an  average  value  of  24 mg/l.  No  values  were
reported in 2018.
o  Both emission points are equipped with equalisation, activated sludge and a
membrane bioreactor,  and seem to be able to achieve lower values than the
maximum reported values.
  In  addition  to  the  above  bullet  points,  taking  into  account  the  assessment  done  for
COD, there is scope for lowering the upper end of the BAT-AEL range.
  Two emission points to water reported concentration values for TOC close to 10 mg/l,
i.e. IT092_w{1} and IT097_w{1}. Both only reported one measurement.
  The proposed lower end of the range is considered appropriate in order to maintain
the empirical analogy between COD and TOC of 3:1.

Footnote (6)
  No information was submitted about the removal efficiency for TOC direct discharge,
and it is not possible to propose a footnote based on  the removal efficiency  without
information.
  Footnote  (6)  refers  to  waste  water  discharged,  not  to  specific  waste  water
consumption. This can be further clarified in the footnote.

Total phosphorus (TP)
  Regarding the comments  to decrease the upper end of the  BAT-AEL range (e.g. to
2 mg/l or 3 mg/l):
o  Concentrations of Total P for direct discharge were reported for 6 emission
points  (DE025_{1},  CZ020_{1},  BE009_{1}  and  {2},  BE010_{1},
BE011_{1}).  All  reported  using  appropriate  monitoring  standards  and
abatement  techniques  (i.e.  apart  from  BE010  which  uses  precipitation  with
FeCl3, all others use coagulation/flocculation). Their maximal concentrations
are between 0.47 mg/l and 1.7 mg/l, except for BE009_{1} which reports  a
maximum  concentration  of  15  mg/l  and  average  of  1.67  mg/l.  The  data
support lowering the upper end of the BAT-AEL range to 2 mg/l.
o  The BAT-AELs are set on collected data and not on other BAT conclusions
(e.g. FDM), voluntary schemes (e.g. ZDHC) or other EU regulations (i.e. the
IED and BAT conclusions are without prejudice to  the Urban Waste Water
Treatment Directive).
  Regarding the comments to increase the upper end of the BAT-AEL range (e.g. to 10
mg/l):
o  Total  P  concentrations  were  reported  for  6  emission  points  (DE022_{1},
DE025_{1},  FR136_{1},  SE118_{1},  SE119  {1},  UK127{1})  from  plants
using  organophosphorus  flame  retardants.  DE022  is  discharging  directly,
others indirectly.  DE022 is also the only one reporting the use of abatement
techniques that would partially remove organophosphates (activated sludge,
coagulation/flocculation  and  sedimentation);  other  plants  use  only
preliminary  or  primary  treatment  (oil/grit  separation,  neutralisation,
equalisation) which is not appropriate for the removal of organophosphates.
The  maximum  concentration  reported  from  DE022  is  0.5  mg/l,  while  the
maximum  concentrations  for  other  plants  (indirect  discharge  and  no
appropriate  abatement)  range  from  5.1  mg/l  (SE119)  to  45  mg/l  (FR136).
SE119  segregates  spent  finishing  liquors  of  organophosphate  flame
retardants  and  removes  them  as  waste,  preventing  them  from  entering
common effluent.
o  It is not clear why plants using organophosphate flame retardants could not
apply  appropriate  abatement  techniques  to  reach  the  proposed  BAT-AEL
range (e.g. like DE022).
  Regarding  the comments to decrease the lower end of the  BAT-AEL range (e.g. to
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0.01 mg/l or 0.1 mg/l): the lowest complete data set (e.g. reporting using monitoring
standards  and  abatement  techniques),  DE025,  reported  a  maximum  concentration  of
0.5  mg/l.  Therefore,  the  data  do  not  support  decreasing  the  lower  end  of  the  BAT-
AEL range to 0.1 mg/l or less.

Total suspended solids (TSS)
  Among  the  plants  that  have  reported  emissions  of  TSS  to  water,  there  are  four
emission  points  to  water  with  maximum  values  between  35 mg/l  and  45 mg/l,  i.e.
UK124_w{1}, IT092_w{1}, PT098_w{1} and DE025_w{1}:
o  UK124_w{1}  reported  more  than  80  measurements  per  year,  with  an
average value around 8 mg/l, while the three maximum concentration values
achieved  in  2016,  2017  and  2018  were  21.7 mg/l,  37.7 mg/l  and  30.4 mg/l,
respectively.
o  IT092_w{1} reported 12 measurements per year within a range from 2 mg/l
to  39.2 mg/l.  3  out  of  36  measurements  were  above  30  mg/l,  achieving  an
average value over the 3 reporting years of 10 mg/l.
o  PT098_w{1}  monitored  TSS  twice  per  year.  The  range  of  the  first
measurement  reported  each  year  was  from  33 mg/l  to  42  mg/l,  while  the
range  of  the  second  measurement  reported  each  year  was  from  10 mg/l  to
18 mg/l.
o  DE025_w{1} monitored TSS with a monthly frequency, and has an ELV for
TSS  of  35  mg/l.  2  out  of  33  measurements  reported  are  above  the  ELV,
while the other measurements are below 24 mg/l.
  Taking into account the measurements detailed in the above bullet points and that all
of the named emission points to water apply at least one of the specific techniques to
remove  solids,  e.g.  coagulation/flocculation,  sedimentation,  filtration  or  flotation,  it
seems  that  the  indicated  emission  points  to  water  are  capable  of  achieving  low
emission levels.

Additional parameters
  No change for nonylphenol, DecaBDE and Sum of PFOA and PFOS.
  To add new footnote associated with indicative emissions levels for BOD related to
COD and TOC BAT-AELs.

Adsorbable organically bound halogens (AOX)
  To decrease the upper end of the BAT-AEL.

Chemical oxygen demand (COD)
  To decrease the upper end of the BAT-AEL

Footnote (4)
  To amend the text to clarify which unit Footnote (4) refers to.

Hydrocarbon oil index (HOI)
EIPPCB
  To add Footnote (2).
proposal:
  To decrease the upper end of the BAT-AEL.

Metals / metalloids

Antimony (Sb)
  To decrease the upper end of the BAT-AEL.

Chromium (Cr)
  To decrease the upper end of the BAT-AEL.

Copper (Cu)
  To change activities/processes to dyeing/printing.

Nickel (Ni)
  To change activities/processes to dyeing/printing.
  To decrease the upper end of the BAT-AEL.
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Zinc (Zn)
  To add footnote (2).

Sulphide, easily released (S2-)
  To decrease the lower end of the BAT-AEL.

Total nitrogen (TN)
  To decrease the upper end of the BAT-AEL.

Footnote (5)
  No change.

Total organic carbon (TOC)
  To decrease the upper end of the BAT-AEL.

Footnote (6)
  To amend the text to clarify which unit Footnote (6) refers to.

Total phosphorus (TP)
  To decrease the upper end of the BAT-AEL.

Total suspended solids (TSS)
  To decrease the upper end of the BAT-AEL.

1.4.6.4
BAT-AELs for indirect discharges to a receiving water body

Location in
P. 735 – Section 5.1.6 – BAT 19 – Table 5.4
D1:
Table 5.4:
BAT-associated emission levels (BAT-AELs) for indirect discharges
to a receiving water body
BAT-AEL (1)
Substance/Parameter
Activities / processes
(2)
(mg/l)
Adsorbable organically bound halogens
All processes
0.1–0.5
(AOX) (3)
Hydrocarbon oil index (HOI)
All processes
1–10
Pre-treatment and/or
dyeing of polyester
Antimony (Sb)
Finishing with flame
0.1–0.4
retardants using
antimony trioxide
Current
Metals / metalloids
Dyeing with
text in D1:
Chromium (Cr)
chromium-containing
0.01–0.3
dyes
Copper (Cu)
All processes
0.03–0.4
Nickel (Ni)
All processes
0.01–0.5
Zinc (Zn)
All processes
0.04–0.5
Dyeing with sulphur
Sulphide, easily released (S2-)
0.3–1
dyes
(1) The averaging periods are defined in the general considerations.
(2)  The  BAT-AELs  may  not  apply  if  the  downstream  waste  water  treatment  plant  is
designed and equipped appropriately to abate the pollutants concerned, provided this
does not lead to a higher level of pollution in the environment.
(3) The BAT-AELs only apply when the substance/parameter concerned is identified as
relevant  in  the  waste  water  stream  based  on  the  inventory  of  inputs  and  outputs
mentioned in 0.

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The associated monitoring is given in 0.

General comments
  Express BAT-AELs as specific loads in kg/ton of treated textile or add an appropriate
expression/factor  (×  m3/t)  for  all  BAT-AELs.  Many  important  BATs  reduce  water
and  energy  consumption,  simultaneously  increasing  the  concentration  of  pollutants
(see also (SE 40)) (SE 27).
  Indicate that indirect discharges are not to the receiving water body but into the sewer
(DE 372).
  Merge  Tables  5.3  and  5.4  into  one  and  refer  to  Footnote  (2),  to  clarify  the
implementation  in  line  with  the  provisions  of  the  IED  (Articles  14(1),  14(3)  and
15(1)) (FR_A 16).
  Adapt the table in line with the proposals made for Table 5.3 in comments EEB 152-
165 (EEB 188).
  Add a further requirement for indirect discharges only, to design and agree a suitable
randomised  sampling  programme  with  the  competent  authority  that  covers  the  full
range  of  discharge  conditions  likely  to  be  encountered  at  the  installation  (e.g.  all  of
the  processing  scenarios  used  during  the  course  of  a  normal  year  of  operations)
(UK 26).

Additional parameters
  Set BAT AEL ranges for:
o  COD < 3000 mg/l;
o  TSS < 200 mg/l;
o  Total N < 50 mg/l;
o  Total P < 10 mg/l;
o  TOC < 700 mg/l.
These  parameters  and  BODx  are  important  to  control  although  the  water  is
treated in a municipal sewage treatment plant. The suggested levels are based on
Summary
the data collected and presented in D1 (SE 27).
of
  Set  a  BAT-AEL  range  for  colour  for  dyeing  activities  as  1/30  dissolution.  This
comments:
parameter is important since it generates a high public response (ES 39).
  Set  a  BAT-AEL  range  for  nonylphenol  to  0.0002-0.005  mg/l  (=  0.2-5  µg/l).
Nonylphenol is a substance of environmental concern. There are 17 data sets for the
value  of  NP,  of  which  13  data  sets  are  in  the  proposed  BAT-AEL  range.  Emission
limit  values  for  this  parameter  are  set  in  some  national  regulations  (e.g.  in  France
0.025 mg/l and in Belgium 0.00008 mg/l) (AT 16).
  Set  a  BAT-AEL  range  for  DecaBDE  to  0.001-0.02  mg/l  because  DecaBDE  is  a
substance  of  environmental  concern  and  should  have  an  ELV  where  relevant.  In
addition,  there  are  5  data  sets  for  the  value  of  DecaBDE.  Finally,  the  use  and
production  of  the  substance  has  been  prohibited  by  the  EU  POP  Regulation
2019/1021 since 2019 (AT 18).
  Set  a  BAT-AEL  range  for  Sum  of  PFOA  and  PFOS  to  0.001-0.003  mg/l  because
PFOA and PFOS are substances of environmental concern. There are 8 data sets for
PFOA and 7 data sets for PFOS. In 2019, PFOA and its salts were listed in category
A (Elimination) in the Stockholm Convention on Persistent Organic Pollutants (entry
into force: December 2020). In the EU, the production, placing on the market and use
of PFOA its salts and polymers have been restricted in Annex XVII to REACH since
2017 (AT 20).

Adsorbable organically bound halogens (AOX)
  Increase  the  upper  end  of  the  BAT-AEL  range  to  1  mg/l.  The  proposed  upper  end
corresponds to the 60th percentile value of the maximum measurements According to
the  data  collection,  the  companies  with  specific  activities  (dyeing  of  PES,  PES/CO,
etc.) report a 90th percentile of the average values corresponding to 1 mg/l. Moreover,
1  mg/l  is  also  10  times  the  environmental  quality  standard  (EURATEX 45,
CEFIC 22).
  If  Hercosett  is  considered  BAT,  add  a  footnote  “In  case  of  antifelting  treatment  of
wool with the Hercosett process, the upper end of BAT-AEL 2.5 mg/l applies.” There
are three installations in Europe that use the Hercosett process in order to increase the
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antifelting qualities of wool. The process has been approved since 60 years ago and is
still demanded by customers who do not want any change in quality. If Hercosett is
considered  BAT,  then  a  footnote  for  a  BAT-AEL  for  indirect  discharge  is  needed,
because – unlike direct discharge – PAC and GAC filtration would not be considered
BAT (AT 49).
  Some of the data sets reported are very low (near the limit of detection) and do not
seem to be credible enough to be used to set BAT AELs (UK 24).

Hydrocarbon oil index (HOI)
  Add Footnote (3) to this parameter (DE 200).
  AT supports the proposed BAT-AEL range (AT 48).
  Some of the data sets reported are very low (near the limit of detection) and do not
seem to be credible enough to be used to set BAT-AELs (UK 24).

Metals / metalloids
  Lower  the  upper  end  of  the  BAT-AEL  range  for  all  metals/metalloids  to  0.2 mg/l.
BAT  for  indirect  discharges  is  to  remove  metals  on  site  with  suitable  pretreatment
(e.g. precipitation, solids removal) (BE 21).
  Add Footnote (3) to this group of parameters (DE 201).
  Same proposals as for parameters in Table 5.3 (DE 373).

Antimony (Sb)
  Increase the upper end of the BAT-AEL range to 0.6 mg/l. It corresponds to the 90th
percentile of the values in the data collection. A higher value should be considered for
the combination of both processes (EURATEX 47).
  Increase  the  upper  end  of  the  BAT-AEL  range  to  1.2  mg/l  for  polyester  and
modacryl/cotton dyeing. Companies with these processes have higher concentrations
of Sb, e.g. according to the data collected 1.0 mg/l (80th percentile) and 1.2 mg/l (90th
percentile). The proposed upper limit does not take into account the majority of well-
performing plants (EURATEX 48).
  Lower the upper end of the BAT-AEL range to 0.2 mg/l. The collected data show that
around 65 % of the plants are below 0.2 mg/l. In addition, experience from Austrian
plants  shows  that  lower  values  can  be  achieved  by  good  chemical  and  water
management (e.g. see BAT 49). Finally, lower values can be achieved with abatement
techniques  nanofiltration,  microfiltration,  ultrafiltration,  prevention  measures
(separate disposal of chemicals) and precipitation. According to national waste water
legislation  (AT  Textile  and  AT  Glas),  0.3  mg/l  Sb  is  achieved  with  prevention
measures (separate disposal of chemicals) and precipitation (AT 47)
  Some of the data sets reported are very low (near the limit of detection) and do not
seem to be credible enough to be used to set BAT-AELs (UK 24).

Chromium (Cr)
  Increase the lower end of the BAT-AEL range to 0.05 mg/l, because the lower limit
should  be  equal  to  environmental  quality  standards  (EQS)  in  the  Water  Framework
Directive.  Treating  waste  water  below  EQS  would  cause  excessive  costs
(EURATEX 46).

Copper (Cu)
  Increase the lower end of the BAT-AEL range to 0.05 mg/l, because the lower limit
should  be  equal  to  environmental  quality  standards  (EQS)  in  the  Water  Framework
Directive.  Treating  waste  water  below  EQS  would  cause  excessive  costs
(EURATEX 46).
  Lower the upper end of  BAT-AEL range to 0.2 mg/l. Add a footnote that, in the case
of increased lightfastness requirements (i.e. use of copper-containing dyes), the upper
end of the BAT-AEL range is up to 0.4 mg/l. According to the collected data, around
65 %  of  the  plants  are  below  0.2  mg/l.  Abatement  technologies  reverse  osmosis,
nanofiltration,  microfiltration  could  be  used  to  achieve  the  concentration  levels
(AT 8).

Nickel (Ni)
  Increase the lower end of the BAT-AEL range to 0.05 mg/l, because the lower limit
should  be  equal  to  environmental  quality  standards  (EQS)  in  the  Water  Framework
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Directive.  Treating  waste  water  below  EQS  would  cause  excessive  costs
(EURATEX 46).
  Lower the  upper end of the  BAT-AEL range  to 0.08  mg/l.  Add a  footnote  that  the
upper  end  applies  to  the  use  of  nickel-containing  dyes.  According  to  the  collected
data, around 70 % of the plants are below 0.08 mg/l. Nickel is a Priority Substance.
Experience  from  Austrian  plants  shows  that  0.08  mg/l  can  be  achieved  with  good
chemical and water management (see BAT 39-42). The plants with emissions values
> 0.05 mg/l do not use abatement technologies such as reverse osmosis, ultrafiltration
or microfiltration (except Plant IT092_w(1)) (AT 10).

Zinc (Zn)
  Increase the lower end of the BAT-AEL range to 0.2 mg/l, because the lower limit
should  be  equal  to  environmental  quality  standards  (EQS)  in  the  Water  Framework
Directive.  Treating  waste  water  below  EQS  would  cause  excessive  costs
(EURATEX 46).

Sulphide, easily released (S2-)
  Footnote  (2)  should  apply  only  to  sulphide,  because  sulphide  can  be  removed  in
activated  sludge  plants  with  adapted  biomass.  All  other  parameters/substances
currently  subject  to  this  footnote  (e.g.  AOX,  HOI,  metals)  are  not  removed  by  the
biological treatment and cannot be subject to such an exemption (AT 12).

Footnote (2)
  Extend the footnote to: "This may be demonstrated by the use of actual data (influent
&  effluent  concentrations  and  flows)  arriving  and  being  discharged  from  the
downstream  WWTW's  or  by  the  use  of  published  data  such  as  sewage  treatment
reduction  factors  that  are  specific  to  the  treatment  provided  at  the  downstream
WWTW's."  The  data  on  the  removal  efficiency  of  downstream  WWTPs  is  not
available  to  the  operator  (confidential  business  information)  to  demonstrate
compliance to the competent authority (UK 25).

General comments
  Regarding the issue on how to express the BAT-AELs, see the assessment done for
direct discharge in Section 1.4.6.3.
  Indirect discharge is defined in the Definitions of the BAT conclusions; therefore, it is
not necessary to clarify the concept of indirect discharge in Table 5.4.
  The  aim  of  having  BAT-AELs  for  indirect  discharge  is  to  protect  the  environment
when the downstream WWTP is not designed to treat the pollutants concerned. With
this objective in mind, it makes sense to have the same levels as direct discharge. For
clarity in implementation, the BAT-AELs for direct and indirect discharge are kept in
separate tables.
  Regarding the comments to change the proposed BAT-AELs, see the assessment of
individual parameters in Section 1.4.6.3 (for direct discharge) and below (for indirect
discharge).
  Monitoring for direct and indirect discharges is addressed in BAT 7.
EIPPCB

assessment:  Additional parameters
  COD, TSS,  Total  N, Total P and TOC  have  not been included in Table  5.4 on the
grounds of the understanding that a downstream treatment plant is, generally, capable
of abating these pollutants,  without any  special provisions. In the rare cases that the
downstream  plant  is  not  capable  of  abating  these  parameters,  the  competent
authorities may apply the BAT-AELs in Table 5.3.
  Regarding  the  comments  for  BOD,  colour,  nonylphenol,  DecaBDE  and  Sum  of
PFOA and PFOS, see the assessment done for direct discharge in Section 1.4.6.3.

Adsorbable organically bound halogens (AOX)
  See the assessment related to direct emissions in Section 1.4.6.3 for use of a statistical
approach or environmental quality standards to derive BAT-AELs.
  Regarding  the  proposals  to  increase  the  upper  end  of  the  BAT-AEL  range  due  to
dyeing of polyester and blends of modacryl/cotton or due to dyeing with vat, metal-
complex  and  reactive  dyes  (assuming  it  is  representative  of  ‘dyeing  products  with
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high  lightfastness,  and  high  quality  demands’),  the  conclusions  are  the  same  as  for
direct discharge (see Section 1.4.6.3). There seem to be no technical grounds (i.e. due
to lack of use of appropriate treatment and many of the plants achieving values below
the proposal) for increasing for upper end of BAT-AELs to a higher value.
  The “Hercosett” process is not considered BAT for shrink-proofing. BAT 51 in D1
promoted  the  use  of  chlorine-free  antifelting,  by  using  inorganic  salts  of
peroxymonosulphuric  acid.  It  is  not  clear,  technically  or  environmentally,  why  the
upper  end  of  the  BAT-AEL  for  indirect  discharge  should  be  increased  to  2.5  mg/l
when the “Hercosett” process is used. Only one plant using this process reported an
AOX  concentration  higher  than  2.5  mg/l,  without  using  appropriate  technique  for
AOX abatement.
  According to the Reference Document on Monitoring of Emissions to Air and Water
from IED Installations (ROM), the measurement range of the EN Standard 9562:2004
is  10-300 μg/l  and  the  proposed  lower  end  of  the  BAT-AEL  range  for  AOX  is
100 μg/l,  i.e.  10  times  higher.  Data  sets  (e.g.  AT006)  in  this  range  are  therefore
considered credible.

Hydrocarbon oil index (HOI)
  It  is  considered  appropriate  to  add  Footnote  (3),  as  oils  in  waste  water  may  not
originate from all processes (i.e. typically from washing synthetic fibres and knitting)
or fibres (i.e. typically from synthetic fibres and knitted fabrics).
  For the assessment related to decreasing the upper end of the BAT-AEL range, see
the assessment in Section 1.4.6.3.
  The lower limit of the measurement range set in EN ISO 9377-2:2000 for HOI is 0.1
mg/l,  10  times  less  than  the  proposed  lower  end  of  the  BAT-AEL.  Data  sets  in  this
range are therefore considered credible.

Metals / metalloids
  It is considered appropriate and consistent with BAT 2 and BAT 7 to add Footnote (3)
to metals for which any specific process is mentioned.
  Depending on the parameter, EPs from well-performing plants have reported values
higher or lower than 0.2 mg/l, for both direct and indirect emissions. It is not clear on
which basis the upper end of the ranges should be lowered to 0.2 mg/l for all metals
indistinctly.  In  addition,  the  aim  is  to  ensure  an  equivalent  level  of  performance  in
both cases (direct and indirect emissions), meaning  that when the downstream waste
water  treatment  plant  is  not  designed  and  equipped  appropriately  to  abate  metal
pollutants,  then  the  textile  plant  ensures  a  similar  level  of  performance  as  for  direct
emissions.
  When similar comments have been received for a given parameter, assessment of the
comments has been done for both direct and indirect emissions.

Antimony (Sb)
  See the assessment related to direct emissions in the previous section.
  According to the Reference Document on Monitoring of Emissions to Air and Water
from  IED  Installations  (ROM)  and  the  EN  Standard  11885:2007,  the  limit  of
detection range for Sb is 4-100 µ/l and the proposed lower end is 100 µ/l.

Chromium (Cr)
  BAT-AELs are derived from the data collection; they are not based on environmental
quality standards referring to the quality of water.
  See the assessment related to direct emissions in the previous section.

Copper (Cu)
  See the assessment related to direct emissions in the previous section.

Nickel (Ni)
  See the assessment related to direct emissions in the previous section.

Zinc (Zn)
  BAT-AELs are derived from the data collection; they are not based on environmental
quality standards referring to the quality of water.
  See the assessment related to direct emissions in the previous section.
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Sulphide, easily released (S2-)
  The  downstream  waste  water  treatment  plant  mentioned  in  Footnote  (2)  may  be  an
urban waste water treatment plant which indeed may not be designed or equipped to
reduce a number of the pollutants targeted by this footnote. However, it may also be
an  industrial  waste  water  treatment  plant  equipped  for  example  with  physico-
chemical  treatment  and  capable  of  abating  AOX,  metals  or  HOI,  in  addition  to
sulphide.
  Regarding BAT-AELs, see the assessment for direct emissions in Section1.4.6.3.

Footnote (2)
  Footnote  (2)  is  used  in  a  number  of  recently  published  BAT  conclusions.  The
verification of the actual removal efficiency of the downstream WWTP seems to be
an implementation issue.

Total P
  Regarding the use of organophosphates as flame retardants and related BAT-AELs,
see the assessment for direct emissions in Section1.4.6.3.

General comments
  No change.

Additional parameters
  No change for nonylphenol, DecaBDE and Sum of PFOA and PFOS.

Adsorbable organically bound halogens (AOX)
  To decrease the upper end of the BAT-AEL range.

Hydrocarbon oil index (HOI)
  To add footnote (3).
  To decrease the upper end of the BAT-AEL range.

Metals / metalloids

Antimony (Sb)
  To decrease the upper end of the BAT-AEL.
EIPPCB

proposal:
Chromium (Cr)
  To decrease the upper end of the BAT-AEL.

Copper (Cu)
  To change activities/processes to dyeing/printing.

Nickel (Ni)
  To change activities/processes to dyeing/printing.
  To decrease the upper end of the BAT-AEL.

Zinc (Zn)
  To add footnote (3).

Sulphide, easily released (S2-)
  To decrease the lower end of the BAT-AEL.

Footnote (2)
  No change.

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1.4.7
Emissions to soil and groundwater

1.4.7.1
Techniques to prevent or reduce emissions to soil and
groundwater

Location in
P. 737 – Section 5.1.7 – BAT 20
D1:
BAT 20. In order to prevent or reduce emissions to soil and groundwater, BAT is to
use all of the techniques given below.

Technique
Description
Applicability
This includes:
  slow  immersion  into  and
withdrawal  of  textile  materials
from  the  process  liquor  to  avoid
spillages;
  automatic  level  adjustment  of
process liquor (see BAT 3);
  avoiding direct injection of water
to heat or cool the process liquor;
  overflow detectors;
Techniques to reduce the

likelihood
and
  channelling  overflows  to  another
environmental  impact  of
tank;
a.

overflows and failures of
  tanks for liquids are located in a
process
and
storage
suitable  secondary  containment;
tanks
their
volume
is
sized
to
accommodate
at
least
the  Generally
complete loss of the liquid of the  applicable
largest  tank  that  is  within  the
Current
secondary containment;
text in D1:
  isolation  of  tanks  and  secondary
containment  (e.g.  by  closing
valves);
  the  surfaces  of  the  process  and
storage areas are impermeable to
the liquids concerned.
The  plant  and  the  equipment  are
regularly inspected and maintained to
ensure
proper
functioning;
this
Regular  inspection  and  includes  in  particular  checking  the
b.
maintenance of plant and  integrity  and/or  leak-free  status  of
equipment
valves,  pumps,  pipes,  tanks  and
containments/bunds  as  well  as  the
proper
functioning
of
warning
systems (e.g. overflow detectors).
The
The storage areas are located in such  applicability
a  way  to  eliminate  or  minimise  the
Optimised
storage
to
existing
unnecessary  transport  of  process
c.
location
of
process
plants  may  be
chemicals  within  the  plant  (e.g.  the
chemicals
restricted  by
transport  distances  on  site  are  space
minimised).
availability
Dedicated
area
for  Hazardous  process  chemicals  are  Generally
d.
unloading
hazardous  unloaded in a bunded area connected  applicable
process  chemicals
to a dedicated drainage system.
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Incompatible  process  chemicals  are
kept  separated.  This  segregation
Segregated  storage  of
e.

relies  on  physical  separation  and  on
process chemicals
the  chemicals  inventory  and  tracking
system (see BAT 14).
Return of unused process chemicals
f.
Unused  process  chemicals  (i.e.  which  remain  in  their  original
containers) are returned to their suppliers.
Packaging  containing  liquid  process
chemicals  is  completely  emptied  by
gravity or by mechanical means (e.g.
Handling  and  storage  of  brushing, wiping) without the use of
g.
packaging
containing  water.  Packaging  containing  process
process chemicals
chemicals in powder is emptied using
suction. Empty packaging is stored in
a dedicated area.

BAT statement:
  Delete  the  words  "or  reduce"  as  the  aim  of  this  BAT  is  to  prevent  emissions
(DE 374).

Whole BAT:
  Move  techniques  (c),  (e)  and  (g)  to  BAT  13  as  part  of  chemical  management.
Optimised  storage  of  chemicals  is  indeed  related  to  chemical  management  (DE 375
and DE 378).

Technique a:
  Add  that  the  9  points  listed  are  applicable  to  new  plants  and  major  plant  upgrades
(EURATEX 50).

Technique d:
  Delete  "connected  to  a  dedicated  drainage  system"  since  drainage  would  be
connected to the common drainage system (DE 376).
  Add  in  the  BAT  statement  the  possibility  to  "use  a  suitable  combination  of  the
techniques  given  below",  or  limit  the  applicability  of  technique  d  to  new  plant  or
major  refurbishments  of  existing  plant.    Many  old  or  historic  sites  could  have
difficulty  due  to  space  constraints  caused  by  the  evolving  layout  of  the  installation
(UK 27).

Summary
Technique f:
of
  Delete bullet point “return of unused process chemicals”, which belongs to BAT 28
comments:
“waste handling” (DE 377).
  Add in the description that unused process chemicals can also be “properly disposed
of”, as suppliers are not obliged to accept the unused process chemicals (IT 22).
  Add  in  the  BAT  Statement  the  possibility  to  "use  a  suitable  combination  of  the
techniques  given  below",  or  mention  that  the  applicability  of  technique  f  may  be
limited.  Many  chemicals  suppliers  could  be  reluctant  to  take  back  used  or  even
unused  process  chemicals  due  to  quality  control  issues  and  restocking  constraints
(UK 27).

Technique g:
  Revise  the  description  as  follows  “powder  products  used  in  small  quantities  are
usually picked up manually with pallets and their packaging is emptied manually. The
widely consumed powders are taken by suction for loading into the automatic dosing
and dissolving plants” (IT 23).
  Mention that the technique is only applicable to major plant upgrades as suction is not
general applicable (EURATEX 49).

Additional technique:
  Add a technique about storage of waste to protect soil and groundwater because it can
cause  emissions  to  soil  and  groundwater,  in  the  same  way  as  process  chemicals
(SE 29).

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BAT statement:
  Not  all  techniques  listed  in  BAT  20  allow  complete  prevention  of  emissions,  for
instance technique a only reduces the likelihood of overflows and failures, which may
nevertheless still happen.

Whole BAT:
  The scope of BAT 13 is the  overall environmental  performance, within the  general
principle  of  the  elaboration  and  implementation  of  a  chemicals  management  system
(CMS) as part of the EMS. On the other hand, techniques e., c. and g. in BAT 20 are
related  to  process  or  equipment  used  in  the  plant,  and  consequently  are  directly
operational.  BAT 13  and  BAT 20  are  indeed  linked  and  this  is  highlighted  in
feature VII  of  BAT 13  which  points  at  BAT 20.  The  link  with  the  overall
environmental performance could be clarified in the statement in BAT 20.

Technique a:
  No rationale has been provided to explain why technically it is needed to change the
applicability of technique a. The listed points are measures commonly applied.

Technique d:
  The dedicated drainage for the area for unloading hazardous process chemicals aims
to  avoid  mixing  the  possible  spillages  with  any  other  effluent  with  low  level  of
pollution such as collected run-off water.
  This being said, the  focus of the techniques is not on the  drainage itself but on the
EIPPCB
dedicated collection and treatment of occasional spillages and this could be reflected
assessment:
in technique d.
  It is not clear technically why it is needed to add an applicability criteria since it is
possible  to  share  an  existing  area  and  to  use  temporary  spillage  collection  devices
when unloading hazardous process chemicals.

Technique f:
  Even though technique f would allow to reduce the risks associated to the storage of
chemicals, the prime objective of technique f is to reduce the amount of waste sent for
disposal and it would be therefore be better placed in BAT 28.
  The return of unused chemicals indeed depends on the agreement of the suppliers, but
it is not clear why such agreement could not be negotiated when placing the order.

Technique g:
  According  to  the  description  of  the  technique  in  Section  4.1.6.6  of  D1,  small
packaging  containing  process  chemicals  in  plastic  or  paper  bags  up  to  25  kg  are
handled manually.

Additional technique:
  The separate collection and storage of waste contaminated with hazardous chemicals
is already covered in BAT 28 b.
  Technique  a  covers  all  types  of  liquids,  including  liquid  waste,  which  could  be
clarified.

  To specify that liquid waste are also addressed by technique a.
  To reword technique d to focus on collection of spillages
EIPPCB
  To add a mention to small packaging in technique g.
proposal:
  To move technique f. to BAT 28
  To complement the statement

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1.4.8
Emissions to air

No comments.

1.4.8.1
Techniques for reducing channelled emissions to air

Location in
P. 738 – Section 5.1.8 – BAT 22
D1:
BAT 22. In order to facilitate the recovery of energy and the reduction of channelled
emissions to air, BAT is to limit the number of emission points.

Description
Current
The combined treatment of waste gases with similar characteristics ensures more effective
text in D1:
and  efficient  treatment  compared  to  the  separate  treatment  of  individual  waste  gas
streams.  The  extent  to  which  the  number  of  emission  points  can  be  limited  depends  on
technical  (e.g.  compatibility  of  the  individual  waste  gas  streams)  and  economic  factors
(e.g. distance between different emission points).

  In the wording of the statement, replace “to limit” with “to optimise” as limiting the
number  of  points  of  emissions  is  not  always  a  feasible  option  for  existing  plants,
taking  into  account  the  type,  nature  and  localisation  of  the  channelled  emissions.  In
addition, this would give flexibility to the competent authorities (IT 24).
  Change the wording of the statement to "BAT is to collect and concentrate the waste
gas streams in as few emission points as technically possible" as the mere limitation
of number of emission points is not sufficient (DE 73).
  Add the following provision to avoid dilution when combining waste gas streams: the
Summary
emissions from the common stack do not exceed the emission level of the individual
of
waste gas streams if they were channelled individually (DE 123).
comments:
  Change the applicability to new plants and major plant upgrades because collecting
all  emissions  is  not  generally  applicable  as  it  can  lead  to  a  higher  concentration  of
pollutants and contribute to a loss of efficiency of the oven (EURATEX 53).
  Change the last sentence of the description into an applicability restriction (IT 25).
  Add an applicability restriction to major refurbishment programmes across the site in
general,  upgrading  to  existing  abatement  technologies  or  replacement  of  existing
thermal  treatment  or  other  processes  which  result  in  significant  emissions  to  air
(UK 28).
  BAT 22  as  proposed  in  D1  focuses  on  the  limitation  of  the  number  of  emission
points,  i.e.  on  the  non-augmentation  of  the  number  of  emission  points  beyond  a
certain  limit.  As  mentioned  in  the  description  of  BAT 22,  this  limit  is  set  by
considering a number of technical and economic factors.  In other words, this limit is
as low as these factors allow, which is equivalent to the proposed wording “optimise”
and  partially  equivalent  to  the  proposed  wording  “to  concentrate  the  waste  gas
streams  in  as  few  emission  points  as  technically  possible.”  The  difference  with  the
latter  is  the  consideration  of  the  economic  factor,  when  for  example  two  emission
points are very far away from each other. In that case, even if technically feasible, it
EIPPCB
may not be economically viable to connect these two emission points.
assessment:
  Concerning the dilution of emissions to air, see the assessment related to the General
considerations, in Section 1.3.1.
  The collection of emissions is covered by BAT 21, not by BAT 22. See the related
assessment in Section 1.4.8.1.
  The principle of limiting the number of emission points per se is generally applicable,
which is reflected in the proposal of D1. This principle can also be applied to existing
plants  and  not  only  to  plant  upgrades.  Of  course,  as  mentioned  in  the  technique
description,  the  extent  to  which  the  number  of  emission  points  can  be  limited  may
vary and depends on technical and economic factors.
EIPPCB
  No change.
proposal:

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1.4.8.2
Techniques for reducing channelled emissions of organic
compounds (e.g. formaldehyde) to air

Location in
P. 738 – Section 5.1.8 – BAT 23
D1:
BAT  23.  In  order  to  reduce  channelled  emissions  of  organic  compounds  (e.g.
formaldehyde)  to  air,  BAT  is  to  use  one  or  a  combination  of  the  techniques  given
below.

Current
Technique
Description
text in D1:
a.
  Condensation
b.
  Ionisation
See Section 5.9.2.
c.
  Thermal oxidation
d.
  Wet scrubbing

General comment about BAT 23
  Add additional information about the abatement techniques such as typical pollutants
targeted, removal efficiency and applicability (DE 274).

BAT statement
  Delete the reference to formaldehyde as only technique c. is relevant for this pollutant
(DE 206, EURATEX 117).

Summary
Technique b.
of
  Delete technique b. as it is not a technique suitable for the removal of volatile organic
comments:
compounds because there is a risk of explosion during use (CZ_B 8).

Additional techniques
  Add electrostatic  precipitator (ESP) as it is an efficient abatement technique  for oil
mist (SE 46).
  Add catalytic oxidation which is used for singeing (DE 74).
  Add  adsorption  which  is  a  well-recognised  technique  for  minimising  emissions  of
organic solvents to air (UK 29).
General comment about BAT 23
  The  format  of  the  table  used  in  BAT 23  is  consistent  with  the  format  used  in  the
recently published BAT conclusions where abatement techniques for emissions to air
are  presented.  In  the  standard  format,  removal  efficiency  is  not  mentioned  but  this
information may be found in other documents such as the CWW BREF.
  Concerning  the  typical  target  pollutants,  they  are  mentioned  in  the  BAT  statement
(i.e. organic compounds including formaldehyde).
  As  mentioned  in  the  General  considerations,  the  BAT  conclusions  are  generally
applicable unless otherwise stated.

BAT statement
  According  to  the  CWW BREF,  scrubbing  is  widely  used  as  a  raw  material  and/or
EIPPCB
product  recovery  technique  for  the  separation  and  purification  of  gaseous  streams
assessment:
which contain  high concentrations of  VOCs, especially compounds  soluble in  water
such as alcohols, acetone or formaldehyde (Section 3.5.1.2.4 of the CWW BREF). It
is  also  a  technique  used  to  abate  formaldehyde  in  the  WBP  and  the  GLS  BAT
conclusions.
  According to the first draft of the WGC BREF (see Section 2.3.2.10.2 of the WGC
BREF),  the  techniques  most  commonly  applied  to  abate  formaldehyde  in  the
chemical sector are:
o  absorption (wet scrubbing);
o  adsorption;
o  condensation;
o  thermal or catalytic oxidation.
  Wet scrubbing and condensation are therefore techniques used to abate formaldehyde.
  Concerning ionisation, no clear evidence has been found that ionisation was used to
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abate channelled emissions of formaldehyde to air.
  The  BAT  statement  has  been  clarified  with  activities/processes  mentioned  in  table
5.5.

Technique b.
  According to the CWW BREF (Section 3.5.1.3.7), ionisation targets the abatement of
VOCs. No specific risk of explosion is mentioned.
  However,  ionisation  is  used  only  for  one  EP  (IT083_{14})  in  combination  with
condensation.

Additional techniques
  Oil mist is not addressed by BAT 23 as it was concluded at the KoM that oil mist was
not a KEI (see Section 4.2 of the KoM report).
  Adsorption  is  used  by  two  plants  of  the  data  collection  (CZ015  uses  adsorption  to
abate emissions from lamination and IT074 to abate emissions from dry cleaning) and
catalytic  oxidation  is  used  only  by  Plant  DE047  to  abate  emissions  from  singeing.
CZ015 is the only plant reporting emission  values  for TVOC, and none of the three
plants have reported values for formaldehyde.
  In  any  case,  even  if  a  technique  is  not  mentioned  in  BAT 23,  it  can  be  used  if  it
ensures at least an equivalent level of environmental protection.

  To delete ionisation.
EIPPCB
  To introduce adsorption.
proposal:
  To harmonize the BAT statement with table 5.5.

1.4.8.3
BAT-AELs for channelled emissions of organic compounds (e.g.
formaldehyde) to air

Location in  P. 738 – Section 5.1.8 – BAT 23 – Table 5.5
D1:
Table 5.5:
BAT-associated emission levels (BAT-AELs) for channelled emissions
of organic compounds (e.g. formaldehyde) to air
BAT-AEL
(Average
Mass flow
over the
Substance/Parameter
Activities / Processes
threshold
sampling
(g/h)
period)
(mg/Nm3)
Coating (1) (2)
Current
Flame lamination (3)
text in D1:
Printing (1) (4)
Singeing
Formaldehyde
1–5
2.5
Thermal treatment in finishing
(1)
Thermal treatment in printing
(1) (4)
Coating
Lamination
TVOC
Printing
3–40 (5)
100
Singeing
Thermal treatment
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(1) The BAT-AEL only applies when formaldehyde is identified as relevant in the waste
gas stream based on the inventory of inputs and outputs mentioned in BAT 2.
(2)  The  BAT-AEL  does  not  apply  where  the  organic  solvent  consumption  for  coating
exceeds 5 tonnes per year.
(3) The BAT-AEL does not apply where the organic solvent consumption for lamination
exceeds 15 tonnes per year.
(4)  The  BAT-AEL  does  not  apply  where  the  organic  solvent  consumption  for  rotary
screen printing exceeds 30 tonnes per year.
(5)  The  lower  end  of  the  BAT-AEL  range  is  typically  achieved  when  using  thermal
oxidation.

The associated monitoring is given in 0.

General comments on the mass flow thresholds
  Clarify the approach for setting the mass flow thresholds (BE 10).
  Delete  the  mass  flow  thresholds  for  all  air  emission  because  they  are  very  low  and
almost no installation reports emissions below the thresholds (DE 379).

Processes concerned
  Add "Thermal treatment with direct heating" as a process concerned for formaldehyde.
Indeed  formaldehyde  is  generally  relevant  for  all  direct  heating  treatments  like
fixation,  heat  setting,  drying  as  well  as  the  thermosol  dyeing  process,  dyeing  with
carriers, etc. and not only for finishing or printing (DE 77).
  Add finishing as a process concerned for formaldehyde and TVOC as these pollutants
may be emitted during finishing (DE 382).

TVOC
  Delete the mass flow threshold, as there are many plants with emissions below 100 g/h
using BAT (e.g. thermal oxidation). In addition, the data show that the proposed mass
flow  threshold  would  exclude  63 %  of  the  emission  points  from  the  BAT’AELs
(AT 26).
  Delete  the  mass  flow  threshold  because  it  is  uncommon  in  BREFs  and  creates
unnecessary complication. If an air stream is channelled and is linked to any of these
activities, it is likely to have loads higher than this (EEB 197).
  Change the BAT-AEL range to 3-20 mg/Nm3 as about two thirds of the reported data
are  below  20 mg/Nm3  and  techniques  are  available  to  achieve  this  level  (AT 25).  In
Summary
addition, some installations reporting high TVOC emissions (e.g. Plants IT074{5} and
of
IT079{3})  use  poor  measurement  techniques,  as  shown  by  the  reported  measurement
comments:
uncertainties of the order of 30-50 % of the measured value. Other measurement data
with  high  TVOC  concentrations  (Plants  DE026  and  DE048)  have  uncertainties  of
2 mg/Nm3, which indicates good quality measurements (EEB 184).
  The lower end of the range may be difficult to monitor with handheld devices which
are proven for use at ELVs of greater than or equal to 6 mg/Nm3 (UK 32).

Formaldehyde
  Check the correctness of the mass flow threshold (2.5 g/h) for formaldehyde (BE 11).
  Delete  the  mass  flow  threshold  because  it  is  uncommon  in  BREFs  and  creates
unnecessary complication. If an air stream is channelled and is linked to any of these
activities, it is likely to have loads higher than this (EEB 196).
  Delete the mass flow threshold because emission points below the proposed mass flow
threshold  are  within  the  BAT-AEL  range.  In  addition,  formaldehyde  is  a  CMR
substance (AT 24).
  Change  the  mass  flow  threshold  to  25 g/h  in  line  with  the  WGC  BAT  conclusions
(CEFIC 23)  and  because  the  mass  flow  of  25 g/h  in  correlation  with  the  proposed
upper end of the range of 5 mg/Nm3 would mean an air flow of 50 000 Nm3/h, which is
more in line with the usual values (EURATEX 51).
  Modify the upper end of the range as follows:
o  10 mg/Nm3 for finishing processes (coating, starching - including combustion
processes  in  thermal  aggregates  with  direct  heating)  and  for  easy-care
finishing, water and soil repellent finishing, thermosol process;
o  15 mg/Nm3 for thermo-fixation;
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o  20 mg/Nm3 for wrinkle-free finishing and flame-retardant finishing.
German LAI14 recommendations are attached to the comment (EURATEX 132, DE 209).
  Increase the upper end of the range to 20 mg/Nm3 for fire retardants applications, easy-
care  and  water  repellence  applications.  Measurement  results  are  attached  to  the
comment (EURATEX 54).
  Change the BAT-AEL range to 1-3 mg/Nm3 because plants with emissions between 3
and 5 mg/Nm3 do not apply BAT (EEB 185).
  Monitoring  data  support  the  application  of  such  a  low  end  of  the  range  for
formaldehyde  based  on  a  limit  of  detection  that  is  1/20  of  the  proposed  1 mg/Nm3
value.  However,  the  extended  sample  time  required  to  achieve  such  a  low  level  of
detection may result in additional costs to operators (UK 31).

Oil mist
  Add a BAT-AEL for emissions of oil mist from thermal treatment, with a range of 1-
8 mg/Nm3 and a mass flow threshold of 100 g/h (SE 30).

Footnote (1)
  Apply  Footnote  (1)  to  singeing  also  because  formaldehyde  is  not  mentioned  as  a
relevant  pollutant  for  singeing  in  Section 2.6.1.1  of  D1  and  because  it  cannot  be
deduced  from  Figure  3.56  in  D1  if  data  on  emissions  of  formaldehyde  also  refer  to
waste gases from singeing (IT 26).

Footnotes (2), (3) and (4)
  In  order  to  ensure  consistency  with  the  IED,  add  the  following  text  at  the  end  of
Footnotes (2), (3) and (4): “(…) and the mass flow of formaldehyde is greater than, or
equal  to,  10 g/h,  an  emission  limit  value  of  2 mg/Nm3  shall  be  complied  with  (IED,
Annex VII, Part 4)” (AT 21, AT 22, AT 23).
  In  order  to  ensure  consistency  with  the  IED,  add  the  following  text  at  the  end  of
Footnotes (2), (3) and (4): “ (…) technical provisions of Part 4, Annex VII to Directive
2010/75/UE apply” (IT 27).
  Delete these footnotes because they are not substantiated. Indeed, these footnotes are
not useful to avoid overlaps between the TXT and the STS BAT conclusions. The final
draft  of  the  STS  BAT  conclusions  covers  consumption  of  organic  solvent  over  200
t/year, leaving an unregulated gap between the values proposed here and the 200 t/year
of the STS BAT conclusions (EEB 194).
  Move  the  application  of  these  footnotes  from  formaldehyde  to  TVOC  because
formaldehyde is not considered to be an organic solvent (CZ_B 9).
  For  the  sake  of  clarity,  delete  Footnotes  (2),  (3)  and  (4)  and  replace  them  with  one
unique footnote that would apply for all processes, for both formaldehyde and TVOC:
“the  BAT-AEL  does  not  apply  for  installations  falling  under  Chapter  V  of  the  IED"
(DE 76).

Additional footnotes
  Add  the  following  footnote  to  TVOC  emissions  in  order  to  clarify  that  legislative
provisions  apply  even  when  the  mass  flow  is  below  the  threshold  of  100 g/h:  “In  the
case  of  a  TVOC  mass  flow  of  less  than  100  g/h,  the  provisions  laid  down  by  the
Directive 2010/75/UE for activities using organic solvents (Chapter V) apply to TVOC
emissions  to  air  from  coating,  lamination  and  printing  processes  where  the  organic
solvent consumptions exceed  the thresholds set out  in the  Part 2 of the  Annex VII to
IED” (IT 28).
  Add a similar footnote to Footnote (1) for TVOC emissions from coating, lamination,
printing and thermal treatment as the BAT-AELs are only relevant if TVOC is present
in  the  waste  gas  streams  from  these  processes,  i.e.  if  organic  solvents  are  used
(CEFIC 24, EURATEX 56).
  Add  a  similar  footnote  to  Footnote  (1)  for  TVOC  emissions  from  thermal  treatment
because  the  BAT  conclusions  also  consider  drying  to  be  a  thermal  treatment  where
VOCs cannot be present in the waste gases (CZ_B 10)

14  Vollzugsempfehlung  Formaldehyd,  Bund/Länder-Arbeitsgemeinschaft  Immissionsschutz,  2015  at  https://www.lai-
immissionsschutz.de/documents/2015-12-09_vollzugsempfehlung_formaldehyd_1503573754.pdf
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 Add the following footnote to TVOC emissions: “an additional mass concentration of
no more than 20 mg/Nm3, to be indicated as total carbon, may be emitted from carry-
overs  and  residues  of  preparations.  The  additional  mass  concentration  only  applies
when using an air-textile goods ratio of 20 m3/kg is used” (DE 380).
 Add  the  following  footnote  to  TVOC  emissions:  “after  deduction  of  measured
emissions of unavoidable unburnt methane, carryover and residual preparations, based
on air- textile- ratio of 20:1 for energy efficiency” (EURATEX 159).
 Add  the  following  footnote  to TVOC  emissions:  “For  existing  direct  heated  thermal
apparatus,  up  to  a  maximum  emission  concentration  of  20 mg C/Nm3  can  be
discounted if it is proven from the unburnt fuel and all possibilities for a reduction have
been  carried  out  (e.g.  like  optimisation  of  burning  process,  minimum  annual
maintenance of the burners)”. This is to account for cases where e.g. unburnt methane
contributes to TVOC emissions (DE 349).
General comments on the mass flow thresholds
 As  mentioned  in  Section 3.5.1  of  D1,  abatement  techniques  are  used  by  only  120
emission points out of 567:
o
Concerning  TVOC,  only  43  emission  points  (EPs)  out  of  the  344  EPs  that
reported TVOC emissions are equipped with techniques to abate emissions of
organic compounds to air, as listed in BAT 23.
o
Concerning  formaldehyde,  only  19  EPs  out  of  the  60  EPs  that  reported
formaldehyde  emissions  are  equipped  with  techniques  to  abate  emissions  of
formaldehyde to air, as listed in BAT 23.
o
Concerning dust, 26 EPs out of the  180 EPs that reported dust emissions are
equipped  with  techniques  to  abate  emissions  of  dust  to  air,  as  listed  in
BAT 24.
o
Concerning  NH3,  4  EPs  out  of  the  27  EPs  that  reported  NH3  emissions  are
equipped  with  techniques  to  abate  emissions  of  NH3  to  air,  as  listed  in
BAT 25.
 This situation where only a  minority of EPs  are equipped with abatement techniques
(12-15 % for dust, TVOC and NH3 and 32 % for formaldehyde) may be explained by
the significance of the emission, which is best appreciated by looking at the emission
mass flows.
 One  could  note  in  particular  that  a  number  of  unabated  emission  sources  are  even
smaller  in  terms  of  mass  flow  than  abated  emission  sources,  as  shown  in  the  graphs
below for TVOC:
EIPPCB
assessment
:
TVOC  emissions  to  air  from  EPs  equipped  with  relevant  abatement  techniques,
expressed in mass flow (g/h)
TVOC  emissions  to  air  from  EPs  not  equipped  with  relevant  abatement  techniques,
expressed in mass flow (g/h)
The  mass  flow  thresholds  proposed  in  D1  attempt  to  reflect  those  cases  where  unabated
emissions  are  already  smaller  than  abated  emissions  and  for  which  abatement  techniques
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would therefore not necessarily be needed.
  The proposed mass flows thresholds are indeed low but a  significant number of EPs
have reported emissions even lower than the mass flow thresholds:
o  TVOC:  209  out  of  the  344  emission  points  that  reported  TVOC  emissions
have a mass flow below 100 g/h.
o  Formaldehyde:  11  out  of  the  60  emission  points  that  reported  formaldehyde
emissions have a mass flow below 2.5 g/h.
o  Dust: 132 out of the 180 emission points that reported dust emissions have a
mass flow below 50 g/h.
o  NH3:  16  out  of  the  27  emission  points  that  reported  NH3  emissions  have  a
mass flow below 50 g/h.

Processes concerned
  Formaldehyde may be a product of combustion of natural gas (in particular methane)
and indeed  the data collection shows  formaldehyde emissions  from  thermal treatment
which  is  not  connected  to  finishing  or  printing  (EP  DE029_{1})  and  this  could  be
better reflected in Table 5.5.
  When  natural  gas  is  burnt,  formaldehyde  emissions  may  be  generated  whatever  the
type of heating (direct or indirect). Considering that the scope of the BAT conclusions
covers both cases, it does not appear necessary to restrict the application of the BAT-
AEL to direct heating only. This  would  also be in line  with the BAT-AEL on TVOC
which applies to both direct and indirect heating.
  According  to  the  definition,  thermal  treatment  includes  fixing  and  heat-setting,  and
process steps of other processes such as pretreatment, dyeing, finishing or printing.
  Based on the data collection, it is not clear whether any emission point  that reported
formaldehyde  or  TVOC  emissions  to  air  is  connected  directly  to  the  wet  finishing
process and/or associated with emissions from other processes (coating or lamination).
It is not clear either how emissions to air would arise from the wet process itself. It is
considered these must be related to the thermal treatment step and it could be clarified
that  finishing  is  a  process  concerned  for  both  formaldehyde  and  TVOC,  and  that
thermal treatment is included as part of the other activities and processes mentioned.

TVOC
  Concerning the mass flow threshold, see the general remarks above.
  When  abatement  techniques  for  TVOC  removal  are  applied,  the  lowest  mass  flows
reported from EPs are around 40 – 50 g/h. Assuming a moderate abatement efficiency
of 80%, gives a conservative unabated (raw) mass flow of 200 g/h, which is considered
an appropriate mass flow threshold for the relevant EPs from the textile processes.
  For emission points without abatement which have:
o  the emission mass flow is below the proposed value, and
o  the emission concentration is between 3 mg/Nm3 and 40 mg/Nm3.
around  71%  of  the  EPs  fulfil  both  conditions.  It  is  considered  that  these  EPs  are  not
significant.  This  could  be  reflected  by  adding  a  footnote  to  acknowledge  when  the
BAT-AEL applies.
  Concerning the upper end of the range, the derivation of the BAT-AELs is not based
on a statistical approach. Even though  two thirds of the plants have reported emission
levels below 20 mg/Nm3, it is not clear why 20 mg/Nm3 should be the upper end of the
range.
  The values reported by emission points IT074{5} and IT079{3} do not correspond to
concentrations but to mass flows expressed in g/h. Plant DE026 has reported maximal
emission concentrations between 30 mg/Nm3 and 70 mg/Nm3 so it is not clear how this
supports  the  lowering  of  the  upper  end  of  the  range  to  20 mg/Nm3.  Plant  DE048  did
not take part in the data collection.
  More  generally  speaking,  out  of  the  326  EPs  which  have  reported  a  monitoring
standard  for  TVOC,  216  have  reported  using  the  standard  EN 12619.  The  use  of  the
same standard ensures an equivalent measurement quality level.
  Concerning  the  lower  end  of  the  range,  the  standard  used  for  monitoring  TVOC  is
EN 12619:2013, which is done by sample extraction and sample filtration followed by
flame ionisation detection. The measurement is not carried out with a handheld device.

Formaldehyde
  Concerning the mass flow threshold, see the general remarks above. While consistency
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with other BAT conclusions is an element to consider, the mass flow threshold in D1
has been proposed on the basis of the data collection for the TXT BREF review, which
differs from the data collection carried out for the drawing up of the WGC BREF.
  Following  the  interventions  of  the  different  TWG  members  during  the  informal
meeting  of  19/02/2021,  it  seemed  that  there  was  not  a  common  position  on  how  to
determine  which  of  the  emission  points  reporting  formaldehyde  emissions  are
considered  relevant  and  would  need  to  comply  with  BAT-AEL,  and  which  are
irrelevant  (or  insignificant  in  terms  of  environmental  impact)  and  would  not  need  to
comply with BAT-AEL. Therefore, the mass flow threshold for this parameter will not
be proposed.
  The air flow reported by the emission points where formaldehyde is measured ranges
from 470 m3/h to 38 100 m3/h, with an average of 12 900 m3/h. It is not clear whether
there is a correlation between the upper end of the range and the mass flow threshold.
  Concerning  the  upper  end  of  the  range,  the  BAT-AELs  are  not  based  on  national
legislation  or  guidelines  but  on  the  data  collection.  According  to  the  data  collection,
none  of  the  plants  that  reported  a  maximum  formaldehyde  concentration  above
5 mg/Nm3 use a technique to abate formaldehyde emissions, except Plant UK127.
  No  information  has  been  collected  about  wrinkle-free  finishing  during  the  data
collection; however, the following is available:
o  EPs  IT094_a{3},  IT094_a{4},  IT094_a{1},  DE042_a{1},  DE032_a{1},
UK127_a{6},  UK127_a{1},  DE050_a{1},  DE023_a{2},  UK127_a{2}  and
UK127_a{4}  apply  flame  retardants  and  have  reported  achieving
formaldehyde  emissions  below  5 mg/Nm3  by  using  one  or  a  combination  of
techniques mentioned in BAT 23;
o  EPs  IT094_a{3},  IT094_a{4},  IT094_a{1},  DE042_a{1},  DE032_a{1},
UK127_a{6}, DE049_a{3}, UK127_a{1}, UK127_a{2}, UK127_a{4} apply
easy-care  finishing  and  have  reported  achieving  formaldehyde  emissions
below  5 mg/Nm3  by  using  one  or  a  combination  of  techniques  mentioned  in
BAT 23;
o  EPs  IT083_a{14},  IT094_a{3},  IT094_a{4},  IT094_a{1},  DE042_a{1},
DE032_a{1},  UK127_a{6},  UK127_a{1},  DE050_a{1},  DE023_a{2},
UK127_a{2}  and  UK127_a{4}  apply  water  repellents  and  have  reported
achieving  formaldehyde  emissions  below  5 mg/Nm3  by  using  one  or  a
combination of techniques mentioned in BAT 23;
o  EPs  UK124_a{1},  UK124_a{6},  UK127_a{6},  UK127_a{1},  UK127_a{2}
and  UK127_a{4}  apply  thermosol  dyeing  and  have  reported  achieving
formaldehyde  emissions  below  5 mg/Nm3  by  using  one  or  a  combination  of
techniques mentioned in BAT 23;
o  EPs  IT094_a{3},  IT094_a{4},  IT094_a{1},  DE042_a{1},  UK124_a{1},
DE032_a{1},  UK124_a{6},  UK127_a{6},  DE050_a{1},  DE023_a{2}  and
UK127_a{4} apply thermofixation and have reported achieving formaldehyde
emissions  below  5 mg/Nm3  by  using  one  or  a  combination  of  techniques
mentioned in BAT 23.
  No  conclusive  evidence  was  found  in  the  data  collection  for  plants  using  abatement
techniques to support the different upper ends for different finishing processes (e.g. 10,
15  or  20  mg/m3).  However,  many  plants  (particularly  from  DE)  not  using  abatement
techniques  did  report  values  around  10  or  20  mg/m3,  respecting  such  emission  limit
values.  The  pollution  reduction  and  control  in  these  plants  is  potentially  ensured  by
process-integrated techniques.
  Plants  DE023  and  DE050  report  emission  levels  between  3 mg/Nm3  and  5 mg/Nm3
and apply wet scrubbing which is a technique to reduce formaldehyde emissions to air.
  Concerning the lower end of the range, the sampling duration reported by the plants of
the data collection which monitor formaldehyde ranges from 0.3 to 6 hours. One of the
plants  that  reported  the  shortest  sampling  period  is  UK124  which  has  reported
formaldehyde  emissions  below  or  close  to  1 mg/Nm3.  Therefore  it  does  not  seem
necessary to mention a longer sampling time for formaldehyde.

Oil mist
  Oil mist is not a KEI as concluded by the TWG at the Kick-off Meeting (see Section
4.2 - Table 1 of the Kick-off Meeting report).

Footnote (1)
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  Footnote  (1)  as  proposed  in  D1  targets  the  emissions  of  formaldehyde  due  to  the
formaldehyde or formaldehyde precursors that may be present in the process chemicals
used in coating, printing or finishing. These formaldehyde emissions can be identified
in the inventory of inputs and outputs, based on the inventory of the process chemicals
used.
  In  addition,  formaldehyde  emissions  are  also  generated  by  the  combustion  of
methane15, which is relevant for singeing, flame lamination and thermal treatment (for
the  latter,  see  the  assessment  above).  In  these  cases,  formaldehyde  emissions  will
always be relevant and Footnote (1) is not necessary.

Footnotes (2), (3) and (4)
  The objective of Footnotes (2), (3) and (4) is to avoid conflict with the provisions of the
IED  (mainly  Part 4  of  Annex VII).  The  BAT  conclusions  do  not  aim  to  repeat  or
interpret  the  IED  provisions  such  as  those  laid  down  in  Part 4  of  Annex VII  and  in
particular in its point 1.
  The footnotes do not aim to avoid overlaps or gaps with the STS BAT conclusions but
to avoid conflict with the provisions of the IED.
  The  footnotes  are  not  linked  to  formaldehyde  being  used  as  organic  solvent  but  to
processes  using  organic  solvent  as  listed  in  Annex VII  to  the  IED  and  generating
emissions of formaldehyde.
  Point 1 in Part 4 of Annex VII states for the processes concerned that “for emissions of
the  volatile  organic  compounds  referred  to  in  Article  58  where  the  mass  flow  of  the
sum of the compounds causing the labelling referred to in that Article is greater than,
or equal to, 10 g/h, an emission limit value of 2 mg/Nm3 shall be complied with. The
emission  limit  value  refers  to  the  mass  sum  of  the  individual  compounds”.  As
formaldehyde is classified as CMR, this means that there could be a conflict with the
IED as the proposed upper end of the BAT-AEL range is 5 mg/Nm3. The same may be
valid for any other CMR substance, which could be clarified in the footnote.
  The  justification  for  the  footnotes as proposed in  D1 could be  unclear to the  reader,
which could be clarified by simply referring to the activities covered by Chapter V of
the IED instead of referring to the activities and solvent consumption thresholds.

Additional footnotes
  Concerning  the  reference  to  Annex  VII  to  the  IED,  as  mentioned  above,  the  BAT
conclusions do not aim to repeat or interpret the IED and it does not seem necessary to
mention that the IED applies, which it does in any case, even if the TVOC mass flow is
greater than the proposed value.
  When  establishing  the  inventory  of  waste  gas  streams  (BAT 2),  the  use  of  organic
solvent  in  a  process  can  be  an  element  of  consideration  when  evaluating  whether
organic compounds are present in the waste gas from this process (for instance in the
case of printing). The use of organic solvent may however not be a determining factor
as  far  as  thermal  treatment  is  concerned,  because  organic  compounds  may  also  be
generated  by  the  evaporation  or  degradation  of  residues  or  of  substances  previously
applied on the textile  fibres and it seems difficult to exclude this  situation  a priori  in
the  inventory  of  waste  gas  streams.  Concerning  coating  and  lamination,  according  to
Section 2.10.3  of  D1,  the  emissions  of  organic  compounds  to  air  are  not  necessarily
linked  to  the  use  of  solvent-based  formulations,  but  also  to  the  use  of  water-based
formulations  (where  dispersing  agents  and  residues  may  be  responsible  for  the
emissions) as well as to the use of coating pastes and melamine resins.
  No  data  have  been  collected  on  the  emissions  due  to  the  carry-over  and  residues  of
preparation.  In  addition,  it  is  not  clear  why  this  would  lead  to  an  additional  emission
concentration of 20 mg/Nm3.
  A  number  of  pieces  of  data  have  been  collected  on  TVOC  emissions  from  directly
heated  systems.  In  these  cases,  the  reported  emissions  include  emissions  from  the
process  itself  and  from  the  combustion  and  have  been  the  basis  for  proposing  BAT-
AELs in D1. It is not clear why 20 mg/Nm3 should be deducted in these cases.
  Concerning the air-textile ratio of 20, see the assessment of the General considerations
in Section 1.3.1.

15 CIMAC Position Paper 04-2014 “Methane and formaldehyde emissions of gas engines”
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  To add finishing as a process for formaldehyde and TVOC.
  To  delete  “thermal  treatment  in  finishing”  and  “thermal  treatment  in  printing”  for
formaldehyde.
  To mention in the BAT statement the processes from which the emissions originate.
EIPPCB
  To delete the proposed mass flow for formaldehyde.
proposal:
  To  add  a  new  footnote  to  restrict  the  applicability  of  the  BAT-AEL  based  on  the
TVOC mass flow without CMR substances.
  To replace Footnotes (2), (3) and (4) with a new footnote and refer to activities covered
by Chapter V of the IED.

1.4.8.4
Techniques for reducing channelled dust emissions to air

Location in
P. 739 – Section 5.1.8 – BAT 24
D1:
BAT 24. In order to reduce channelled dust emissions to air, BAT is to use
one or a combination of the techniques given below.
Current

text in D1:
Technique
Description
a.
Cyclone
b.
Electrostatic precipitator (ESP)
See Section 5.9.2.
c.
Wet scrubbing

  Change  the  BAT  statement  to  state  that  cyclones  can  only  be  used  in  combination
with other abatement techniques, as the upper end of the range of the proposed BAT-
AELs cannot be achieved with a cyclone alone (UK 30).
  Add fabric filters to the list of techniques as they can achieve low levels of emissions,
Summary
are used for mechanical processes in textile processing or dye handling and have been
of
reported by various plants (IT061 and IT096) (DE 79, IT 29, EEB 195).
comments:
  Add absolute  filters to the  list of techniques as dust  filtration systems allowing the
achievement of the dust emissions at the lower end of the proposed BAT-AEL range.
In addition, those techniques  are efficiently being used, e.g. by IT061, IT072, IT083
and IT094 (IT 29).
  According  to  the  data  collection,  4  EPs  are  equipped  with  cyclones  as  the  only
abatement  technique  and  have  reported  dust  emissions  to  air  up  to  6.1 mg/Nm3
(IT078_a{4}, PT115_a{4}, IT069_a{1} and PT115_a{11}). These EPs are related to
singeing and thermal treatment in finishing.
  However, cyclones are generally used as pre-treatment, as is mentioned for example
in the WT BAT conclusions.
  Two  EPs  are  equipped  with  bag  filters  (IT061_{3}  and  IT061_{4}),  with  dust
emissions  to  air  of  8.5 mg/Nm3  and  2.5 mg/Nm3  respectively.  The  dust  emissions
originate from beating and folding of wool.
  Two EPs are equipped with absolute filters (IT083_{15} and IT072_{4}), with dust
emissions  to  air  of  0.4 mg/Nm3  and  6.8 mg/Nm3  respectively.  EP  IT083_{15}  is
EIPPCB
associated  with  weighing  of  hydrosulphite  and  EP  IT072_{4}  is  associated  with
assessment:
pressing and packaging.
  EP IT094_{02} reported the use of a bag filter but did not report dust emissions.
  Bag  filters  and  absolute  filters  are  therefore  used  to  abate  dust  emissions  from
handling  textile  material  or  process  chemicals  but,  according  to  the  data  collection,
they are not used to abate dust emissions from the processes addressed in Table 5.6,
i.e.  singeing,  fabric  production  or  thermal  treatment.  This  could  be  clarified  in  the
BAT statement.
  In any case, the techniques listed in BAT 24 are neither prescriptive nor exhaustive.
Other  techniques  may  be  used  that  ensure  at  least  an  equivalent  level  of
environmental protection.

  To mention that cyclones are generally used as pre-treatment.
EIPPCB
  To  mention  in  the  BAT  statement  the  processes  from  which  the  dust  emissions
proposal:
originate (see the assessment in Section 1.4.8.5).

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1.4.8.5
BAT-AEL for channelled dust emissions to air

Location in
P. 739 – Section 5.1.8 – BAT 24 – Table 5.6
D1:
Table 5.6:
BAT-associated  emission  level  (BAT-AEL)  for  channelled  dust
emissions to air
BAT-AEL
(Average over
Mass flow
Activities /
Substance/Parameter
the sampling
threshold
Processes
period)
(g/h)
Current
(mg/Nm3)
text in D1:
Fabric production
Dust
Singeing
< 1–10
50
Thermal treatment

The associated monitoring is given in 0.

Processes concerned
  Delete  thermal  treatment  because  normally  there  is  no  dust  emission  from  thermal
treatment (however dust may be relevant for combustion process for heat production
or directly heated stenters if other fuel besides LPG or natural gas is used) (DE 80).
  Delete  fabric  production  and  thermal  treatment  because  dust  emissions  are  only
relevant for singeing (DE 383).
  Add  "handling  processes  with  solids  like  dyes"  as  another  activity  concerned
(DE 80).

Threshold
  Delete  the  mass  flow  threshold  because  it  is  uncommon  in  BREFs  and  creates
unnecessary complication. If an air stream is channelled and is linked to any of these
activities, it is likely to have loads higher than this (EEB 198).
  Delete  the  mass  flow  threshold  because  many  emission  points  below  the  proposed
mass flow threshold are within the BAT-AEL range and therefore BAT. In addition,
there are many plants below 50 g/h using abatement techniques and about 75 % of the
emission points are below 50 g/h and excluded from the BAT-AEL (AT 27).

BAT-AEL range
  Lower the upper end of the range to 5 mg/Nm3 and consider lowering the lower end
Summary
to take into account the good performance of fabric filters (EEB 199).
of

comments:
  Increase the upper end of the range to 20 mg/Nm3 to account for emissions due to the
quality  of  the  textile  and  not  to  the  burning  of  fuel  (e.g.  if  cotton  is  singed  with
medium- and low-quality cotton and organic cotton, because this might cause higher
emissions  of  burnt  cotton  dust,  e.g.  due  to  low  staple  length,  increased  hairiness)
(EURATEX 160).
  Increase  the  upper  end  of  the  range  to  50 mg/Nm3  and  the  mass  flow  threshold  to
250 g/h  because  these  values  cannot  be  reached  by  using  only  BAT.  To  do  so,  it
would  be  necessary  to  install  abatement  techniques  at  all  stacks,  which  may  not  be
possible due to product quality (CZ_B 78).
  Increase the lower end of the range to 5 mg/Nm3 because demonstrating compliance
at  such  low  levels  is  likely  to  prove  extremely  challenging  for  operators  and  their
monitoring  contractors  and  will  likely  result  in  additional  costs  for  the  monitoring
programme. In particular:
o  it  is  not  clear  how  many  of  the  collected  data  are  from  results  reported  as
less  than  values,  which  will  have  an  associated  high  level  of  uncertainty
attached to them;
o  the  scope  of  the  standard  EN 13284-1:2017  is  stated  as  being  “up  to
50 mg/Nm3 and typically 5 mg/Nm3”;
o  the standard EN 13284-1:2017 specifies that the overall field blank must be
< 10 %  of  the  ELV;  an  ELV  of  1 mg/Nm3  would  require  a  field  blank  of
< 0.1 mg/Nm3, which may not be possible to achieve;
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o  the standard specifies that the expanded uncertainty of the result should not
exceed  20 %  of  the  ELV;for  an  ELV  of  1 mg/Nm3  this  means  that  the
maximum allowable uncertainty should not exceed 0.2 mg/Nm3; this is less
than the limit of detection of the standard (UK 33).

Additional footnotes
  Add a footnote to emissions from singeing mentioning that the upper end of the range
could  be  20 mg/Nm3  if  cotton  is  singed  with  medium-  and  low-quality  cotton  and
organic  cotton,  because  this  might  cause  higher  emissions  of  burnt  cotton  dust,  e.g.
due to low staple length, increased hairiness (DE 214).
  Add a footnote to emissions from thermal treatment mentioning that the BAT-AEL
does not apply if natural gas is used as fuel (EURATEX 57).

Processes concerned
  Dust emissions have been reported for 83 EPs associated with thermal treatment. This
does not concern heat production, which is not in the scope of the BAT conclusions.
Of these 83 EPs, 77 are connected to direct heating (i.e. the flue-gas is in contact with
the  textile)  and  64  of  these  77  EPs  are  connected  to direct  heating  with  natural  gas.
The dust emissions from these 64 EPs range from 0 mg/Nm3 to 24.1 mg/Nm3.
  Of the 83 EPs associated with thermal treatment, 4 are connected to indirect heating
and report dust emissions from 0.5 mg/Nm3 to 4 mg/Nm3.
  This shows that dust emissions are also relevant in those cases, possibly coming from
the textile material itself.
  Dust  emissions  from  fabric  production  have  been  reported  from  13  EPs  and  range
from 1.1 mg/Nm3 to 23 mg/Nm3. However, after further analysis, it appears that these
13 EPs are all connected to thermal treatment (e.g. to dryers or stenters) and not to the
fabric production itself (e.g. knitting or weaving).
  Dust may also be generated from handling process chemicals in the form of powder
but little data were reported about such emissions (the EPs concerned are IT072_{3},
IT072_{4} and IT_96_{1}).
  Besides singeing, dust emissions seems to be generated as a thermal treatment step in
processes  such  as  dyeing  (e.g.  PT109_{5},  ES058_{24},  IT137_{6}),  printing  (e.g.
PT108_{10}, ES058_{28}) or finishing (e.g. CZ015_{4}, CZ015_{3}, PT117_{4}).
This could be reflected in the title of the table.

Threshold
  Regarding the deletion of mass flow thresholds in the TXT sector, see the assessment
EIPPCB
of comments related to Table 5.5 in Section 1.4.8.3.
assessment:
  When  abatement  techniques  for  dust  removal  are  applied,  the  lowest  mass  flows
reported from EPs are around 10-15 g/h. Assuming a moderate abatement efficiency
of  80%,  gives  an  unabated  (raw)  mass  flow  of  50 g/h,  which  is  considered  an
appropriate mass flow threshold for the relevant EPs from the textile processes.
  For the emission points without abatement which have:
o  either an emission mass flow below 50 g/h;
o  or  an  emission  concentration  below  10 mg/Nm3  (proposed  upper  end  of
BAT-AEL).
the average gas flow is 4 800 Nm3/h and the median is 3 100 Nm3/h.
  Based on the  small  mass  flows emitted,  around 63% of the  EPs  without abatement
fulfil both conditions, it is considered that these EPs are not significant. This could be
reflected by adding a footnote to acknowledge when the BAT-AEL applies.
  CMR  substances  could  be  bound  on  particulate  matter  (dust).  Such  dust  emissions
could  have  significant  environmental  impact,  therefore,  the  emission  point  would
need to comply with BAT-AEL.

BAT-AEL range
  According to the data collection, fabric filters are not used for the processes targeted
in Table 5.6.
  The  BAT-AELs  proposed  in  D1  are  based  on  the  values  reported  via  the  data
collection. The reported values are values measured at the emission points, therefore
including dust from the combustion and from the textile itself and it is not clear why
the upper end of the range should be increased to 20 mg/Nm3.
  The proposed upper end of the range is based on the data collection and reflects the
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emission  levels  which  are  achieved  by  plants  of  the  data  collection  when  applying
one  or  a  combination  of  the  techniques  listed  in  BAT 24.  If  an  unabated  emission
point cannot achieve this level, it may be necessary to install an abatement technique
but it is not clear why it would not be possible due to product quality.
  Concerning  the  lower  end  of  the  range,  while  the  measurement  uncertainty  could
increase as a percentage at lower emission levels, it should be noted that 17 EPs have
reported dust emission levels below 1 mg/Nm3.
  It is also stated in EN 13284-1 that increasing the “sampling time to 60 min or to 90
min would naturally improve significantly the reproducibility of measurements”.
  The proposed lower end of the range is also consistent with the levels that have been
considered appropriate for other BAT conclusions (e.g. STS).

Additional footnotes
  No information has been collected via the data collection or made available about the
dust  emissions  to  air  from  singeing  of  medium-  and  low-quality  cotton  or  organic
cotton.
  As  mentioned  above,  dust  emissions  to  air  have  also  been  reported  from  thermal
treatment burning natural gas, possibly coming from the textile material itself.
  To  amend  the  title  of  Table 5.6  to  identify  the  processes  for  which  the  BAT-AEL
EIPPCB
applies.
proposal:
  To add a new footnote to restrict the applicability of the BAT-AEL based on the dust
mass flow.

1.4.8.6
Techniques for reducing channelled ammonia emissions to air

Location in
P. 739 – Section 5.1.8 – BAT 25
D1:
BAT 25. In order to reduce channelled ammonia emissions to air, BAT is to
use wet scrubbing.
Current
text in D1:

Description
See Section 5.9.2.
Summary
  Add adsorption as an additional technique because otherwise the BAT is prescriptive.
of
In addition, the applicability of the BAT may be limited by the waste water treatment
comments:
plant capacity (CEFIC 13).
  As mentioned in the General  considerations, these BAT are neither prescriptive nor
EIPPCB
exhaustive. Other techniques  may be  used that ensure at least an equivalent  level of
assessment:
environmental protection.
EIPPCB
  To mention in the BAT statement the processes from which the emissions originate
proposal:
(see the assessment of BAT 24 in Section 1.4.8.4).

1.4.8.7
BAT-AEL for channelled ammonia emissions to air

Location in
P. 739 – Section 5.1.8 – BAT 25 –Table 5.7
D1:
Table 5.7:
BAT-associated emission level (BAT-AEL) for channelled ammonia
emissions to air
BAT-AEL (1)
Mass flow
Current
(Average over
threshold
text in D1:
Substance/Parameter
Activities / Processes
the sampling
(g/h)
period)
(mg/Nm3)
Coating
NH3
3–10
50
Printing
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Thermal treatment in
finishing
Thermal treatment in
printing
(1) The BAT-AEL only applies when NH3 is identified as relevant in the waste gas stream based
on the inventory of inputs and outputs mentioned in BAT 2.

The associated monitoring is given in 0.

  Delete  the  mass  flow  threshold  as  many  emission  points  below  the  proposed  mass
flow  threshold  are  within  the  BAT-AEL  range  and  therefore  BAT.  There  are  many
plants below 50 g/h using abatement techniques and about 64 %  (16 emission points
out of 25) of the emission points are below 50 g/h and excluded from the BAT-AEL
(AT 28).
  Increase the upper end of the range to 20 mg/Nm3 for fire retardant processes as the
proposed upper and of the range is not achievable for such processes (e.g. when using
Summary
ammonium sulphamate) (FR_B 7, EURATEX 59).
of
  Add a footnote mentioning that the upper end of the range is 30 mg/Nm3 for plants
comments:
producing  technical  textiles,  PPE  (personal  protection  equipment)  or  other  textiles
which need to comply with safety standards such as flame retardance. This is because
flame retardant finishing of technical textiles and PPE leads to higher NH3 emissions
and wet scrubbing is not applicable as  a low waste gas temperature leads to adverse
conditions of the waste gas (DE 347, EURATEX 161).
  Concerning the lower end of the range, the value proposed of 3 mg/Nm3 is likely to
lead  to  additional  monitoring  costs  for  the  operator  associated  with  monitoring  for
longer periods in order to achieve the stated limit of detection required (UK 34).
  Regarding the deletion of mass flow thresholds in the TXT sector, see the assessment
of comments related to Table 5.5 in Section 1.4.8.3.
  Only  4  our  if  34  plants  reporting  ammonia  emissions  use  appropriate  abatement
technique (i.e. wet scrubbing). They report mass flows from 21 g/h to 168 g/h. 27 EPs
that report not using the abatement techniques  have  mass  flows  from 0.1 g/h to 666
g/h. The related processes included coating, printing and finishing (same as the plants
using abatement), but also others like dyeing and shrink-proofing. It is not clear why
they  do  not  use  abatement  techniques,  since  none  of  them  reported  using  process
integrated techniques e.g. to reduce urea use in printing.
  Following  the  interventions  of  the  different  TWG  members  during  the  informal
meeting  of  19/02/2021,  it  seemed  that  there  was  not  a  common  position  on  how  to
determine which of these emission points are considered relevant and would need to
comply  with  BAT-AEL,  and  which  are  irrelevant  (or  insignificant  in  terms  of
environmental impact) and would not need to comply with BAT-AEL. Therefore, the
mass flow threshold for this parameter will not be proposed.
  Based  on  the  data  collection  many  of  the  emission  points  related  to  Functional
EIPPCB
finishing. It was not clear whether they are originating from the wet treatment or the
assessment:
following  thermal  treatment  step.  Therefore,  it  was  considered  best  to  specify  that
BAT-AELs relate to thermal treatment associated with finishing (and other processes
included in Table 5.7 like coating and printing).
  Concerning the upper end of the range, Plant BE010 uses ammonium sulphamate for
flame-retardance  finishing,  which could explain the level of NH3 emissions (up to a
concentration  of  16 mg/Nm3  and  a  mass  flow  of  264 g/h).  However,  this  plant  does
not use  wet scrubbing to abate the ammonia emissions to air and it is not clear why
the  upper  end  of  the  range  should  be  increased  to  20 mg/Nm3  or  30 mg/Nm3.  Since
this  substance  is  alternative  to  using  brominated  flame-retardants  the  footnote  for
increased upper end of the BAT-AEL range could accommodate the plants using it.
  It  is  not  clear  how  a  low  waste  gas  temperature  would  prevent  the  use  of  wet
scrubbing. In addition, the waste gas temperature reported by Plant BE010 is between
64 °C and 95 °C.
  Concerning  the  lower  end  of  the  range,  it  may  indeed  be  necessary  to  extend  the
sampling  duration  according  to  standard  EN ISO 21877.  In  D1,  this  is  reflected  in
Footnote (1) of the table for emissions to air in the General considerations.
EIPPCB
  To add that all Activities/Processes concerned include associated thermal treatment.
proposal:
  Delete the mass flow threshold.
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 To add footnote for upper end of the range in case of using ammonia-based
substances in flame retardant finishing.

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1.4.8.8
Techniques for reducing emissions of organic compounds to air
from thermal treatment of synthetic textile materials

Location in
P. 740 – Section 5.1.8 – BAT 27
D1:
BAT 27. In order to reduce emissions of organic compounds to air from the thermal
treatment of synthetic textile materials, BAT is to wash them.
Current

text in D1:
Description
Synthetic textile  materials are  washed prior to thermal treatment. If needed, the  washing
water is sent to treatment (see BAT 19).

  Link this BAT to BAT 23 as it also concerns emissions of organic compounds to air
(FR_A 17).
  Add the following words at the end of the BAT statement “(…) or use techniques to
reduce  the  emissions  to  air”  because  in  certain  applications  it  is  necessary  to  apply
thermofixation to thin synthetic textiles before washing them (SE 31).
  Add  the  possibility  of  treatment  of  emissions  to  air  as  an  alternative  to  washing
Summary
(EURATEX 60).
of
  Add other techniques or open the formulation, because otherwise the BAT would be
comments:
prescriptive as it mentions only one technique (CEFIC 15).
  Add an applicability clause to consider that:
o  depending on product specifications, such a washing is not applied;
o  depending on the pace of production, washing the fabric may lead to mould
development (FR_A 17).
  Clarify when a treatment is needed for the  washing water because it is not obvious
why the washing water would not need any treatment. (FR_A 18).
  BAT 27 is about emissions of organic compounds. As it is a primary technique (i.e.
process-integrated  technique)  and  not  a  secondary  technique  (i.e.  abatement
technique), it would be clearer and more logical to have this BAT placed immediately
before BAT 23. The same applies for BAT 26.
  Section 4.4.6  of  D1  mentions  that  some  synthetic  knitted  fabrics  need  to  be
thermofixed before washing; however, no further details are available.
  This being said, Section 4.4.6 of D1 focuses on synthetic knitted fabrics and not on
synthetic fibres because knitted fabrics may contain more residual preparation agents
than woven fabrics, in particular knitting oil, which may end up in emissions to air if
the  fabrics  are  not  washed  before  thermal  treatment.  This  could  be  reflected  in
BAT 27.
  The thermal treatment which is referred to here is thermofixation. As mentioned  in
Section 2.6.4.1 of D1, thermofixation is a step of the pretreatment of synthetic textile
EIPPCB
material. This could be reflected in BAT 27.
assessment:
  Concerning  the  applicability  restriction  due  to  textile  characteristics  such  as  thin
fabrics or due to product specifications, no information has been made available as to
why the textile material concerned needs to undergo thermofixation before washing.
  As  mentioned  in  the  General  considerations,  BAT  are  neither  prescriptive  nor
exhaustive. Other techniques  may be  used that ensure at least an equivalent  level of
environmental protection.
  Concerning the development of mould on wet textile materials, this seems rather to be
an  operational  consideration  which  can  be  addressed  when  planning  the  production
operations.
  The washing water contains the preparation agents removed from the textile materials
(e.g. knitting oil) but could in principle be reused without treatment if the content of
impurities  allows  (see  BAT 9).  In  any  case,  the  reuse  and  treatment  of  water  is
already covered by other BAT and it does not seem necessary to repeat it in BAT 27,
the focus of which is emissions to air.
  To move BAT 27 before BAT 23.
EIPPCB
  To focus BAT 27 on the washing of knitted synthetic fabrics prior to thermofixation.
proposal:
  To delete the reference to water treatment.

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1.5
BAT conclusions for the pre-treatment of raw wool fibres
by scouring

1.5.1
Techniques for using resources efficiently and for reducing
water consumption and waste generation

Location in
P. 742 – Section 5.2 – BAT 29
D1:
The  BAT  conclusions  in  this  section  apply  to  the  pre-treatment  of  raw  wool  fibres  by
scouring and apply in addition to the general BAT conclusions in Section 5.1.

BAT 29. In order to use resources efficiently as well as to reduce water consumption
and waste water generation, BAT is to recover wool grease and recycle waste water.
Current

text in D1:
Description
Waste  water  from  wool  scouring  is  treated  (e.g.  by  a  combination  of  centrifugation  and
sedimentation)  to  separate  grease,  dirt  and  water.  Grease  is  recovered,  water  is  partially
recycled to scouring and dirt is sent to further treatment.

Summary
of
  No comments.
comments:
EIPPCB
  Not applicable.
assessment:
EIPPCB
  No change.
proposal:

1.5.2
BAT-AEPLs for the recovery of wool grease from the pre-
treatment of raw wool fibres by scouring

Location in
P. 742 – Section 5.2 – BAT 29 – Table 5.8
D1:
Table 5.8:
BAT-associated  environmental  performance  levels  (BAT-AEPLs)
for the recovery of wool grease from the pre-treatment of raw wool fibres
by scouring
BAT-AEPL
Type of wool
Unit
(Yearly average)
Coarse wool (i.e.
wool fibre
Current
11–15
diameter typically
text in D1:
higher than 35 µm)
kg of recovered grease per tonne of
Extra and super
raw wool pre-treated by scouring
fine wool (i.e.
wool fibre
50–60
diameter typically
lower than 20 µm)

The associated monitoring is given in BAT 5.
  Amend the proposed BAT-AEPL range for kg of wool grease recovered from coarse
wool to 10-15 kg/t. The data submitted  from the 2 UK plants  show  that the average
achieved over the last 3 years would fit a range of 10-15 kg/t of raw wool processed
Summary
and not a range of 11-15 kg/t (UK 36).
of
  Change  the  BAT-AEPL  range  for  “Extra  and  super  fine  wool”  to  40-60 kg  of
comments:
recovered grease per tonne of raw wool pretreated by scouring. Indeed, due to global
warming  and  worse  conditions  for  sheep  breeding  in  general,  the  lower  value  of
50 kg/t has shifted to 40 kg/t for some wool (CZ_B 75).
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  The BAT-AEPLs have been determined on the basis of the data collection. According
to  the  data  reported  by  UK128  and  UK129  for  quantity  of  wool  grease  recovered
EIPPCB
from coarse wool, there is scope to decrease the lower end of the range to 10 kg/t.
assessment:
  Regarding the range for “Extra and super fine wool”, it is not clear on exactly which
data the modified range values could be based.
EIPPCB
  To decrease the lower end of the range  for quantity of wool grease recovered from
proposal:
coarse wool.

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1.6
BAT conclusions for the production of yarn and fabric

1.6.1
Techniques for reducing emissions to water

Location in
P. 744 – Section 5.3 – BAT 32
D1:
The  BAT  conclusions  presented  in  this  section  apply  to  the  production  of  yarn
and fabric and apply in addition to the general BAT conclusions in Section 5.1.

BAT  32.  In  order  to  reduce  emissions  to  water  from  the  use  of  sizing
chemicals, BAT is to use all of the techniques given below.

Technique
Description
Applicability
Sizing
chemicals
with
improved
environmental  performance  in  terms  of
Current
Selection
of  quantity needed, washability, recoverability
text in D1:
a.

sizing chemicals
and/or  biodegradability  (e.g.  modified  Generally
starches, certain galactomannans, polyvinyl  applicable
alcohol and certain polyacrylates) are used.
The cotton  yarns are dipped into hot  water
Pre-wetting
of
b.

prior  to  sizing.  This  allows  a  reduction  of
the cotton yarns
the amount of sizing chemicals.
The  fibre  strands  are  compressed  by  The  applicability
Compact
suction  or  by  mechanical  or  magnetic  may  be  restricted
c.

spinning
compacting. This allows a reduction of the  by
product
amount of sizing chemicals.
specifications

Technique a.
  Delete  “polyvinyl  alcohol  and  certain  polyacrylates”  which  have  a  worse
environmental  performance,  and  polyvinyl  alcohol  is  biodegradable  only  under
certain conditions. In the current Austrian waste water ordinance on textiles, there is
one  BAT  conclusion  recommending  the  replacement  of  polyvinyl  alcohol  (AT 45,
EURATEX 118).
  Add that yarns and fabrics with such sizing chemicals are purchased at the end of the
description.  This  is  to  clarify  that  the  correct  choice  of  size  applies  not  only  to  the
choice  of  the  sizing  chemical  but  also  to  the  choice  of  yarn  or  fabric  purchased
(EEB 42).Add  a  reference  to  BAT  36  below  the  table.  Indeed,  selecting  based  on
recoverability  is  BAT,  but  so  is  actually  recovering  which  is  described  in  BAT  36
(EEB 42).
  Replace  generally  applicable  with  “applicability  may  be  restricted  by  product
Summary
specifications”.  Product  specifications  sometimes  require  specific  sizing  chemicals
of
which  cannot  be  recovered  or  are  not  biodegradable  (e.g.  sizing  of  PES  yarns)  (
comments:
EURATEX 63).

Technique b.
  Restrict  the  applicability  as  follows:  "Generally  applicable  if  it  does  not  lead  to  a
higher  energy  consumption  and  if  compatible  with  operational  constraints,  sizing
equipment  or  product  specifications”.  This  technique  may  not  be  compatible  with
high-speed weavers. This can lead to bad "sizing" performance and the cotton fibres
have to be dried for longer; this will increase the energy consumption and need a big
investment for one material only (FR_A 55, EURATEX 58).

Technique c.
  Replace  "by  product  specifications"  with  "in  line  with  the  descriptions  in  Section
4.3.1.2.3" (EEB 110).
Technique a.
  According to Sections 4.3.1.2.1, 4.1.7.3.5.4.1 and 4.1.7.4.3 of D1, polyvinyl alcohol
EIPPCB
and certain polyacrylates are indeed only biodegradable under certain conditions, but
assessment:
are  widely used. These substances are  mentioned  in  brackets as examples and could
be deleted from the description of technique a.
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  This BAT refers to the sizing process, while the choice of yarn or fabric purchased is
covered in BAT 4 (a).
  Although  sizing  chemicals  are  part  of  BAT  36 b,  a  link  between  both  BAT  would
apply only when sizing and desizing are done in the same plant.
  It  is  not  clear  why  biodegradable  sizing  agents  could  not  be  used  on  the  polyester
yarns.

Technique b.
  According  to  Section  4.3.1.2.2  of  D1,  there  are  no  technical  restrictions  to  the
applicability  restriction  of  this  technique,  and  in  particular  there  is  no  information
about  a  poorer  performance  of  the  sizing  step  and  no  reference  to  the  product
specifications or operational constraints. Concerning sizing, existing sizing machines
with two  sizing boxes can be upgraded by using the  first sizing box for pre-wetting
and the second one for sizing and it is not clear why it could not technically be done.
Finally,  concerning  the  energy  consumption,  more  energy  may  indeed  be  needed  to
dry the cotton yarns but on the other hand this technique leads to an increase in sizing
machine speed of about 22 %.

Technique c.
  Examples from Section 4.3.1.2.3 of D1such as hairiness of the yarns would facilitate
the understanding of the applicability of technique c.

  To delete “polyvinyl alcohol and certain polyacrylates” in technique a.
EIPPCB
  To add an example in the applicability restriction of technique c.
proposal:

1.6.2
Techniques for using energy efficiently

Location in
P. 745 – Section 5.3 – BAT 34
D1:
BAT 34. In order to use energy efficiently, BAT is to use technique a and one or both
of techniques b and c given below.

Technique
Description
This includes:
  reducing  the  volume  of  the  production  area  to  reduce  the
Use  of  common
a.

amount of energy needed for humidifying the ambient air;
techniques
  using advanced sensors that detect thread breaks to stop the
spinning or weaving machines.
This includes:
  using lighter spindles and bobbins in ring frames;
  using spindle oil with optimal viscosity;
Current

text in D1:
  maintaining an optimal oiling level of the yarn;
Use  of  common
  optimising  the  ring  diameter  with  respect  to  the  yarn
b.

techniques
in
diameter in ring frames;
spinning
  gradual start-up of the ring spinning machines;
  using vortex spinning;
  optimised  movement  of  empty  bobbin  conveyors  in  cone
winding machines.
This includes:
Use  of  common
c.

techniques
in
  avoiding excessive air pressure for air-jet weaving;
weaving
  using a double-width loom for large-volume batches.

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Technique a.
  Change  the  applicability  of  technique  a.  to  "applicable  to  new  plants  or  major
upgrades  of  plants",  as  a  reduction  of  the  volume  of  the  production  area  requires  a
change  of  the  configuration  of  the  installation  (FR_A 56,  UK 39,  CEFIC 25,
Summary
EURATEX 62, EURATEX 162).
of

comments:
Technique c.
  Change  the  applicability  of  technique  c.  to  "Applicable  to  new  plants  or  major
upgrades of plants". Changing the  whole configuration of  the production area  is  not
always possible (UK 39).
Technique a.
  According  to  Section  4.3.2.1  of  D1,  one  way  to  reduce  the  volume  of  the
production area is to install a suspended ceiling, which does not seem to be a
major  plant  upgrade  which  is  defined  as  “a  major  change  in  the  design  or
technology of a plant with major adjustments or replacements of the process.”
EIPPCB
This example could however bring clarity to the technique description.
assessment:
Technique c.
  Replacing  an  existing  loom  with  a  double-width  loom  would  indeed  be  a
major plant upgrade according to the definition mentioned above.
  The names of the techniques a, b and c could be related to energy savings to
make them technically more relevant.
  To add the example of suspended ceiling in technique a.
EIPPCB
  To add an applicability criteria related to the double-width loom in technique c.
proposal:
  To amend the name of the techniques a, b and c.
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1.7
BAT conclusions for the pretreatment of textile materials
other than raw wool fibres

1.7.1
Techniques  for  using  energy  efficiently  and  reducing  water
consumption and waste water generation

Location in
P. 746 – Section 5.4 – BAT 35
D1:
The BAT conclusions in this section apply to the pre-treatment of textile materials other
than raw wool fibres and apply in addition to the general BAT conclusions in Section 5.1.

BAT  35.  In  order to  use  energy  efficiently  as well  as to  reduce  water  consumption
and waste water generation, BAT is to use both of the techniques given below.

Current
text in D1:
Technique
Description
Applicability
Combined  pre-
Various  pre-treatment  operations  of  cotton  Only applicable to
a.  tr eatment
of  textiles  (e.g.  desizing,  scouring  and  new  plants  or
cotton textiles
bleaching) are carried out simultaneously.
major
plant
Cold  pad-batch  Desizing  and/or  bleaching  are  carried  out  upgrades
b.  tr eatment
of  with  the  cold-pad  batch  technique  (see
cotton textiles
Section 5.9.4).

  Delete technique a. or link it to BAT 15 since it contradicts enzymatic pretreatment
Summary
(EURATEX 119).
of
  Amend  the  applicability  so  that  both  techniques  a.  and  b.  are  generally  applicable.
comments:
The  proposed  techniques  may  be  implemented  even  at  the  occasion  of  minor
upgrades (SE 33, UK 40).
  It is not clear how technique a. contradicts enzymatic pretreatment described in BAT
15.
  According  to  the  information  in  Section  4.4.3  in  D1,  existing  plants  with  new
machinery suitable for this process could apply this technique.  In addition, 20 plants
from the data collection have reported using technique a.
EIPPCB
  Regarding an applicability restriction for technique b., according to Section 4.5.1.8 in
assessment:
D1, there are no technical restrictions to the applicability of this technique.
  Taking into account that techniques a. and b. of BAT 35 can also be applied to use
resources efficiently, there is justification for merging BAT 35 with BAT 36, as both
have the same environmental objectives.

  To provide more examples in the description of technique a. (see assessment done in
Section 1.4.3.1 for technique b.).
EIPPCB
  To change the applicability of techniques a. and b.
proposal:
  To merge BAT 36 with BAT 35.

1.7.2
Techniques for using resources and energy efficiently and
reducing water consumption and waste water generation

Location in
P. 746 – Section 5.4 – BAT 36
D1:
BAT 36. In order to use resources and energy efficiently as well as to reduce water
consumption and waste water generation, BAT is to use one of the techniques given
below.

Current
text in D1:
Technique
Description
Applicability
A  single  desizing  liquor  is  used  to  remove
Single  desizing  different  types  of  sizing  chemicals.  This  Generally
a.

liquor
solution  is  strongly  alkaline  (pH  higher  applicable
than 13) and contains hydrogen peroxide.
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When  desizing  is  carried  out  by  washing  Only applicable in
with  hot  water,  water-soluble  sizing
Recovery
and
plants
where
chemicals  (e.g.  polyvinyl  alcohol  and
reuse  of  water-
sizing
and
b.

polyacrylates)  are  recovered  from  the
soluble
sizing
desizing
are
washing  water  by  ultrafiltration.  The
chemicals
carried  out  at  the
concentrate  is  reused  for  sizing,  whereas  same plant
the permeate is reused for washing.

Technique a.
  Delete  technique  a.  The  desizing  method  depends  on  the  sizing  agent  used  and  a
single desizing liquor for all sizing agents is not reasonable (DE 319).
  Delete “This solution is strongly alkaline (pH higher than 13) and contains hydrogen
peroxide”. Some sizing agents like polyvinyl alcohol precipitate in alkaline solutions,
so  the  formulation  of  the  single  desizing  liquor  needs  to  be  adapted  (FR_A 60,
EURATEX 64).
Summary
  Add that applicability may be restricted by product specifications. The conditions of
of
desizing  are  not  always  as  mentioned  in  the  technique  description,  e.g.  PES  warm
comments:
washing is carried out without hydrogen peroxide (EURATEX 65).

Technique b.
  Add  that  applicability  may  be  restricted  by  product  specifications;  not  all  sizing
chemicals can be recovered from the washing water by ultrafiltration e.g. PES sizing
(EURATEX 66).
  Add a reference to BAT 32 (EEB 45).

Technique a.
  According to Section 4.4.1 of D1, there are no technical restrictions to the use of the
same  desizing  liquor  for  various  sizing  chemicals.  On  the  contrary,  Section  4.4.1
mentions that the use of a single desizing liquor is particularly suitable when several
products are used.
  As  for the  exact characteristics of the  desizing  solution, this  may  indeed change  to
take into account the specificities related to the sizing chemicals used.
EIPPCB

assessment:  Technique b.
  The  technique  aims  to  recover  water-soluble  chemicals  from  the  washing  water  by
ultrafiltration. According to Section 4.4.8.1 of D1, this technique is suitable for water-
soluble chemicals, as stated in the BAT description.
  According to Section 4.4.8.1 of D1, more examples of water-soluble sizing chemicals
could be added.
  Although sizing chemicals are part of BAT 32, a link between both BAT would apply
only when sizing and desizing are done in the same plant.

  To merge BAT 36 with BAT 35 (see assessment in Section 1.7.1).
EIPPCB
  To remove the second sentence in the description of technique a.
proposal:
  To add carboxymethyl cellulose as an example of water-soluble sizing chemicals.

1.7.3
Techniques for preventing or reducing emissions to water of
chlorine-containing compounds and complexing agents

Location in
P. 746 – Section 5.4 – BAT 37
D1:
BAT  37.  In  order  to  prevent  or  reduce  emissions  to  water  of  chlorine-containing
compounds and complexing agents, BAT is to use one or both of the techniques given
Current
below.
text in D1:

Technique
Description
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Bleaching  is  carried  out  with  chlorine-free  bleaching
Chlorine-free
a.

chemicals (e.g. hydrogen peroxide, peracetic acid or ozone),
bleaching
possibly catalysed with enzymes.
The use of complexing agents can be completely avoided or
minimised  by  reducing  the  concentration  of  hydroxyl
radicals during bleaching. This is achieved by:
Optimised

hydrogen
  using demineralised water;
b.

peroxide
  prior removal of metal impurities from textile materials
bleaching
(e.g. by magnetic separation or chemical extraction);
  controlling the pH and the peroxide concentration during
bleaching.

Technique a.
  Delete “possibly catalysed with enzymes” as enzymes are not stable in  combination
with peroxide (EURATEX 120).
  Add  the  following  applicability  clause  “the  applicability  may  be  restricted  by  the
characteristics of the textile materials and/or product specifications” (IT 31).
  Hypochlorite bleaching is needed for some specific fabrics (EURATEX 67).

Technique b.
Summary
  Replace  “demineralised  water”  with  “softened  water”.  Demineralised  water  is  not
of
necessary to reduce the need for complexing agents, and will increase  the amount of
comments:
waste baths (CZ_B 12, FR_A 58, EURATEX 67).
  Add  information  on  applicability  or  delete  “magnetic  separation”;  magnetic
separation works with magnetisable elements (DE 320, EURATEX 121).
  Delete “chemical extraction” because it is unclear and may imply the use of solvent
(DE 320).
  Add an additional bullet point: "pretreatment of textile fabrics (removal of Mn and Fe
residues)” (EURATEX 67).

Technique a.
  During the 2nd Data Assessment Workshop held on 21-23 October 2020, EURATEX
clarified  that  enzymes  are  used  as  a  pretreatment,  before  bleaching.  This  can  be
clarified in the description of technique a.
  According  to  the  data  collection,  several  plants  reported  using  enzymes  in
combination with peroxide for bleaching (DE034, DE040, FR131, IT097 and PT108).
  Although this technique seems widely used, examples have been reported where this
technique may not apply, and this could be reflected in the applicability.

Technique b.
EIPPCB
  The replacement of “demineralised water” by “softened water” would be in line with
assessment:
the EIPPCB proposal for BAT 15 (see Section 1.4.5.3).
  Obviously, magnetic  separation will function only with  ferromagnetic  metals and it
does not seem necessary to mention it in the BAT conclusions.
  The term “chemical extraction” refers in fact to two methods which are mentioned in
Section  4.4.7.2  of  D1:  acid  demineralisation  and  reductive  treatment.  This  term  can
indeed be misleading as it could be understood from it that solvent is used. This could
be clarified by replacing “extraction” with “treatment”.
  Pre-washing of textiles could also be used to reduce the presence of metal impurities.
  According  to  Section  4.4.7  of  D1,  it  is  relevant  to  check  the  decomposition  of
hydrogen peroxide. This could be clarified in the description.

  To clarify the use of enzymes in the description of technique a.
  To add an applicability restriction to technique a.
EIPPCB
  To  replace  the  terms  “demineralised”  and  “chemical  extraction”  and  to  add  a
proposal:
reference to pre-washing in technique b.
  To clarify the need to control of the hydrogen peroxide concentration.

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1.7.4
Technique for using resources efficiently and for reducing the
amount of alkali discharged to the waste water treatment

Location in
P. 747 – Section 5.4 – BAT 38
D1:
BAT  38.  In  order  to  use  resources  efficiently  and  to  reduce  the  amount  of
alkali  discharged  to waste water  treatment,  BAT is  to  recover  caustic soda
used for mercerisation.
Current

text in D1:
Description
Caustic  soda  is  recovered  from  the  rinsing  water  by  evaporation  and  further
purified, if needed.

  Modify the applicability as it may be restricted by product specifications, or add an
applicability  criteria  to  new  plants  or  plants  with  major  upgrade.  Difficulties  to
reconcentrate the soda can occur (EURATEX 76).
Summary
  Add  an  applicability  restriction  as  when  distillation  process  recovers  alkali  from
of
mercerising,  the  alkali  rinsing  water  is  heated  up  and  the  water  is  evaporated  and
comments:
condensed.  Distillation  needs  a  lot  of  energy  to  heat  the  liquor  and  evaporate  the
water (EURATEX 122).

  It  is  not  clear  technically  which  difficulties  can  restrict  the  applicability  of  this
technique. According to the data collection, several plants that have different products
achieve the proposed BAT-AEPL.
EIPPCB
  According to the data collection, several plants (e.g. FR134, DE030, PT108, UK127
assessment:
ES058  and  BE013)  are  using  this  technique  and  did  not  report  more  energy
consumption than other plants not using evaporation to recover caustic soda from the
rinsing water.

EIPPCB
  No change.
proposal:

1.7.5
BAT-AEPL for the recovery of caustic soda used for
mercerisation

Location in
P. 747 – Section 5.4 – BAT 38 – Table 5.9
D1:

Table 5.9:
BAT-associated environmental performance  level  (BAT-AEPL) for
the recovery of caustic soda used for mercerisation
BAT-AEPL
Parameter
Unit
(Yearly average)
Current
Recovery of caustic soda used for
text in D1:
%
75–95
mercerisation

The associated monitoring is given in BAT 5.

Summary
  No comments.
of

comments:
EIPPCB
  Not applicable.
assessment:

EIPPCB
  To simplify the table.
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1.8
BAT conclusions for dyeing

Location in
P. 748 – Section 5.5.
D1:
Current
Entire Section 5.5.
text in D1:
  Shorten  and  simplify  the  techniques,  just  including  the  major  ones  with  proven
environmental  impact  and  proven  applicability.  Indeed  a  lot  of  BATs  include
extensive lists of techniques, which are extremely detailed for different sub-processes,
types  of  dyes,  raw  materials  etc.  This  degree  of  detail  leads  to  an  unnecessary
complexity, which might complicate the implementation of the BAT conclusions via
permits and/or national binding rules. In addition, a number of BATs might contradict
each other, are common practice (e.g. pH control), are just dyeing processes without
any reference to a specific BAT (e.g. cold pad-batch dyeing), are not applicable at all
(e.g.  vat  dyeing  without  steaming),  are  wrong  interpretations  of  BAT  candidates  in
Chapter 4 (e.g. printing carried out without urea) (DE 393).
  Specify the techniques called "optimised process" (or using similar expressions). The
added value of the BAT conclusions would be higher if there was a common picture
Summary
in  Europe  on  what  "optimised  processes"  are.  In  the  descriptions  of  the  BAT
of
conclusions  there  are  examples  of  those  processes,  but  the  relevance  of  the
comments:
descriptions is quite low in comparison with the technique itself (DE 393).
  Add  in  BAT  39  and  BAT  40  a  missing  technique  which  is  described  in
Section 4.5.1.4  of  D1  (optimised  removal  of  unfixed  dyestuff  in  reactive  dyeing)
(CZ_B 13):

Technique
Description
Applicability
Unfixed
dyestuff
is
removed  from  the  textile
Optimised removal of  materials
by
using

unfixed  dyestuff  in  enzymes
and/or
vinyl  Generally applicable
reactive dyeing
polymers. This reduces the
number  of  rinsing  steps
needed.

  Concerning  the  comments  about  the  complexity  of  the  BAT  conclusions  related  to
dyeing  and  the  use  of  the  wording  “optimised  process”,  they  are  relatively  general
and are not specific as to why exactly they would need to be changed. See the BAT-
specific assessments below for the assessment of specific proposals for modifications.
EIPPCB
  Concerning the additional technique proposed, it is already proposed in BAT 39c in
assessment:
D1.  The  proposed  addition  about  the  reduction  of  rinsing  steps  could  bring  further
clarity though.
  It  is  not  clear  why  this  technique  would  need  to  be  repeated  in  BAT 40  which  is
specific to cellulosic fibres.
EIPPCB
  To add a reference to the reduction of rinsing steps in BAT 39c.
proposal:

1.8.1
Techniques for using resources efficiently and reducing
emissions to water

Location in
P. 748 – Section 5.5 – BAT 39
D1:
The BAT conclusions in this section apply to dyeing and apply in addition to the
general BAT conclusions in Section 5.1.

Current
BAT  39.  In  order  to  use  resources  efficiently  and  to  reduce  emissions  to
text in D1:
water  from  dyeing,  BAT  is  to  use  one  or  a  combination  of  the  techniques
given below.

Technique
Description
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Technique for batch and continuous dyeing
Dyes without dispersing agents are used or, where this is
a.

Selection of dyes
not
possible,
with
dispersing
agents
that
are
biodegradable (e.g. based on fatty acid esters).
Techniques for batch dyeing
For  textile  materials  with  zwitterionic  characteristics,
dyeing  is  carried  out  at  constant  temperature  and
b.

pH-controlled dyeing
controlled  by  gradually  lowering  the  pH  of  the  dyeing
liquor below the isoelectric point of the textile materials.
Optimised  removal  of  Unfixed  dyestuff  is  removed  from  the  textile  materials
c.

unfixed
dyestuff
in  by using enzymes (see BAT 15 b) and/or vinyl polymers.
reactive dyeing

Technique a.
  Delete  the  use  of  dyes  without  dispersing  agent  because  disperse  dyes  cannot  be
formulated  and  applied  in  water-based  systems  without  dispersing  agents.  Indeed,
disperse  dyes  are  only  in  a  metastable  state  and  will  precipitate  quickly  without
dispersing agents (DE 236, EURATEX 123).
  Expand  technique  a.  to  a  more  general  technique  on  the  selection  of  dyes  because
technique a. is too restrictive and move the use of biodegradable dispersing agents to
BAT 42 (UK 41).

Technique b.
  Add  that  the  pH  for  wool  dyeing  depends  on  the  dyestuff  class  and  is  normally
selected in a manner so that exhaustion of the dye is maximal and wool damage kept
Summary
at a minimum (DE 321).
of
  Move technique b to BAT 40 and BAT 41 because it is also relevant for continuous
comments:
dyeing  and  expand  it  as  follows  because  it  is  too  restrictive:  “dye  profiles  and
chemical  additions  are  optimised  and  controlled,  i.e.  amounts  of  dye  and  chemical,
temperatures and pH control to the material being dyed.” (UK 41).

Technique c.
  Delete technique c. because there is no known application (DE 237).
  Delete technique c. because it is in contradiction with BAT 40f (EURATEX 69).
  Add that the applicability of this technique is restricted by the characteristics of the
textile materials and/or product specifications (IT 32).
  Move technique c. as worded to BAT 40 and expand technique BAT 39c. as follows:
“Unfixed  dye  removal  is  optimised  to  reduce  water  and  surfactant  use  while
maintaining the required fastness specifications” (UK 41).
Technique a.
  Section 4.5.1.1  of  D1  mentions  that  pre-reduced  liquid  sulphur  dyes  without
dispersing  agents  are  provided  for  all  kinds  of  fabric.  Nothing  similar  is  mentioned
for other types of dyes. After further investigation, no clear evidence has been found
that dispersant-free dyes were used on an industrial scale, for any type of dyes.
  The selection of dyes is already addressed in BAT 13 as all other process chemicals.
  According to Section 8.6.3 of D1, dispersing agents are contained in vat, sulphur and
disperse dyes and may be added in other classes of dyes. The technique therefore fits
better  in  BAT 39  which  concerns  all  types  of  dyes  than  in  BAT 42  which  concerns
only disperse dyes.
EIPPCB

assessment:  Technique a1.
  New  information  was  submitted  to  EIPPCB  by  the  TWG  (supporting  document  to
comment  DE  408).  The  technique  promotes  dyeing  with  levelling  agents  from
recycled vegetable oil. These agents can be used in batch or continuous processes.

Technique b.
  This  technique  is  used  for  fibres  with  zwitterionic  behaviour  such  as  wool,
polyamide, silk, etc. Section 4.5.1.5 of D1 does not contain specific information about
the pH selection for wool dyeing and no information has been made available about
this.  Moreover,  the  technique  does  not  concern  the  selection  of  pH  as  such  but
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describes  the  principle  of  controlling  the  dyeing  process  by  progressively  lowering
the pH.
  pH is indeed not the only parameter to be controlled for dyeing. Amounts of dye and
auxiliary  chemicals,  temperature  and  amount  of  textile  materials  are  also  important
parameters  that  need  to  be  controlled  and  monitored.  This  is  covered  by  BAT 3.
BAT 39 does not refer to the monitoring and control of dyeing parameters in general
but  to  a  specific  technique,  only  applicable  to  textile  material  with  zwitterionic
characteristics, which consists of keeping the temperature constant and changing the
pH  instead  of  keeping  the  pH  stable  and  changing  the  temperature,  which  allows
energy  savings.  It  is  not  clear  whether  this  technique  can  be  used  for  continuous
dyeing.

Technique c.
  Technique c. has been reported by Plants IT089 and IT090.
  Both  BAT 39  and  BAT 40  state  that  BAT  is  to  use  one  or  a  combination  of  the
techniques  described  in  these  BAT.  It  means  that  technique  BAT  39c  and  BAT  40f
are  not  necessarily  used  at  the  same  time.  Moreover,  deleting  technique  BAT  39c
would result in a loss of information as it does not concern only dyeing of cellulosic
materials (which is the case of BAT 40).
  It  is  not  clear  which  characteristics  of  the  textile  materials  and/or  product
specifications may limit the applicability of this technique.
  The optimised removal of unfixed dyestuff does not concern only dyeing of cellulosic
fibres and seems therefore better placed in BAT 39 than in BAT 40.
  Concerning the proposed wording, the objective of the technique is indeed to have an
optimal removal of unfixed dyestuff, in the sense that it reduces water and surfactant
use  while  maintaining  the  required  fastness  specifications.  However  this  does  not
describe the technique, i.e. how it is done.

  To remove the reference to dispersant-free dyes from the description of technique a.
EIPPCB
  To  add  new  technique  a1  on  dyeing  with  levelling  agents  made  from  recycled
proposal:
vegetable oil.

Location in
P. 748 – Section 5.5 – BAT 40
D1:
BAT  40.  In  order  to  use  resources  efficiently  and  to  reduce  emissions  to
water  from  the  dyeing  of  cellulosic  materials,  BAT  is  to  use  one  or  a
combination of the techniques given below.

Technique
Description
Applicability
Technique for dyeing with sulphur dyes
Dyeing  is  carried  out  without  sodium
sulphide  or  hydrosulphite  as  reducing  The  applicability
Minimised  use  agents.
may  be  restricted
a.  o  f sulphur-based  Where  this  is  not  possible,  partially  by
product
reducing agents
chemically  pre-reduced  dyes  (e.g.  indigo
Current
specifications
dyes) are used so that less sodium sulphide
text in D1:
or hydrosulphite is added for dyeing.
Technique for continuous dyeing with vat dyes
May
not
be
Vat  dyes  are  selected  to  enable  dyeing
Selection  of  vat
applicable
to
b.

without subsequent steaming, oxidising and
dyes
dyeing  with  dark
washing.
shades
Techniques for dyeing with reactive dyes
Use  of  high-
Use  of  poly-functional  reactive  dyes  with
c.  fi  xation  reactive  more than one reactive functional group.
Generally
dyes
applicable
Use  of  cationic  Dyeing  is  carried  out  on  cationic  cotton,
d.

cotton
which does not require the use of salts.
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Only applicable to
Cold  pad-batch  Dyeing  is  carried  out  with  the  cold  pad-
new
plants
or
e.

dyeing
batch technique (see Section 5.9.4).
major
plant
upgrades
Rinsing  after  dyeing  with  reactive  dyes  is
carried out at a high temperature (e.g. up to
Optimised
Generally
f.

95 °C)  and  without  using  detergents.  The
rinsing
applicable
heat  of  the  rinsing  water  is  recovered  (see
BAT 10 f).
Techniques for continuous dyeing with reactive dyes
In
cold
pad-batch
dyeing
(see  May
not
be
Use
of  Section 5.9.4.), concentrated aqueous alkali  applicable
to
g.

concentrated
solutions  without  sodium  silicate  are  used  dyeing  with  dark
alkali solution
for the fixation of dyes.
shades
The  applicability
may  be  restricted
by
the
The  reactive  dyes  are  fixed  with  steam,
Steam  fixation
characteristics  of
h.

which  avoids  the  use  of  chemicals  for
of reactive dyes
the
textile
fixation.
materials  and  by
product
specifications

Technique a.
  Change  the  applicability  restriction  to  “generally  applicable”  as  the  only  restriction
mentioned  in  Chapter 4  of  D1  is  that  some  colours  may  not  be  available.  The
restriction based on product specifications is too wide (EEB 111).
  Make reference to sulphur and vat dyes (as should Section 4.5.2.1 of D1) to put this
technique  into  context.  In  addition,  specify  the  use  of  alternative  reducing  agents  as
given in Section 4.5.2.1 especially the use of glucose which has been widely adopted
(UK 42).

Technique b.
  Delete technique b. because  vat dyeing cannot be carried out without steaming and
oxidising (DE 322, EURATEX 124).

Technique c.
  Change  the  applicability  of the  technique  to reflect  that  it  may be restricted by the
characteristics of the textile materials and/or product specifications (IT 33, UK 42).
  Mention  that  the  degree  of  fixation  not  only  depends  on  the  number  of  reactive
groups but also on the affinity and build-up behaviour of a dye molecule (DE 322).

Summary
Technique d.
of
  Delete technique d. because the chemicals to produce cationic cotton are carcinogenic
comments:
and skin-sensitive (DE 239, DE 322).
  Change  the  applicability of the  technique to reflect that  it  may be restricted by the
product  specifications  (EURATEX 68)  and/or  characteristics  of  the  textile  materials
(UK 42).

Technique e.
  Delete technique e. because it does not have added value: cold pad-batch is one of the
most simple applications and is widely used (DE 322).

Technique f.
  Change  the  applicability of the  technique to reflect that  it  may be restricted by the
characteristics of the textile materials and/or product specifications (IT 34).
  Change the applicability of the technique to new plants or major plant upgrades and if
it is economically feasible. Indeed the thermal energy needs to be sufficiently high for
recovery and there needs to be a use for the recovered heat (EURATEX 70).
  Combine technique f. with BAT 39c. as they are both about the same technique but
cover different aspects (UK 42).
  In  view  of  energy  use,  this  BAT  is  questionable.  There  are  new  generation  dyes
available  which  offer  the  opportunity  to  wash  off  at  lower  temperature,  with  less
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water and reduced washing off agents (DE 322).

Technique g.
  There  are  different  application  processes:  processes  with  no  sodium  silicate
(processes using caustic soda or a combination of caustic soda and soda ash) are more
popular (DE 322).

Technique h.
  Specify the applicability restrictions with information from Chapter 4 of D1 as it is
too vague (EEB 112).
  Pad steam dyeing is a normal application process (DE 322).
Technique a.
  Section 4.5.2.1 of D1 explains that the use of alternative reducing agents may lead to
differences of shade compared to common sulphur dyeing. The shade required by the
product specifications may therefore limit the applicability of this technique and this
could be reflected in the BAT conclusions.
  Section 2.7.3.3 of D1 mentions that the reducing agents used for vat dyes are mainly
hydrosulphite  and  sulphoxylic  acid  derivatives  (zinc  sulphoxylate),  the  latter  being
used when the pad-steam process is applied. It is mentioned that sulphur-free organic
reducing agents such as hydroxyacetone are also available for some applications.
  According to Section 9.1 of D1, indigo dyes are a kind of vat dye.

Technique b.
  Section 4.5.1.2.  of  D1  mentions  that  in  some  cases  vat  dyeing  can  be  carried  out
without  steaming  and  subsequent  washing  (pad-dry  process).  No  comments  were
made  on  Section 4.5.1.2  and  it  is  not  clear  why  this  technique  is  not  feasible.
Furthermore,  no  conclusion  was  taken  at  the  Kick-off  meeting  to  remove  this
technique.
  This technique was reported by plant PT 105.

Technique c.
  Concerning  the  applicability  of  this  technique,  the  comments  are  not  specific  as  to
which textile materials and/or product specifications would limit its applicability.
  The  degree  of  fixation  of  a  dye  depends  indeed  on  its  substantivity  for  the  fibre.
Technique  c  however  is  specific  to  use  of  polyfunctional  reactive  dyes,  not  to  the
high-fixation dyes in general, which could be clarified in the name of the technique.
EIPPCB

assessment:  Technique d.
  It is not clear which product specifications or textile materials may limit the use of
cationic cotton.
  According to one comment received on Section 4.1.5.3.2 of D1, cationisation solution
is produced and distributed by INOTEX (CZ). Cationisation is therefore a technique
which is used.
  The  cationisation  agent  is  3-chloro-2-hydroxypropyltrimethylammonium  chloride
(CHPTAC)  which  is  suspected  to  be  carcinogenic.  In  the  waste  water  from  the
cationisation  process,  CHPTAC  goes  through  an  intermediate  reactive  stage  and
forms 2,3-epoxypropyltrimethylammonium chloride (EPTAC), which is carcinogenic
and  a  skin  sensitiser.  Section 4.1.5.3.2  of  D1  mentions  alternative  eco-friendly
substances to CHPTAC based on chitosan but these are still under development.

Technique e.
  A total of 7 of the 105 plants from the data collection have reported using cold pad-
batch  dyeing  (DE026,  IT059,  IT064,  IT065,  IT068,  IT094  and  PT114).  This  shows
that, although well-known, this technique is not overwhelmingly used.

Technique f.
  It  is  not  clear  which  product  specifications  or  textile  materials  may  limit  the
applicability of this technique.
  BAT 39c  and  BAT 40f  present  two  options  for  optimal  rinsing,  which  are  not
necessarily  carried  out  at  the  same  time.  In  that  sense,  both  techniques  could  be
merged. However, BAT 39c is relevant for all types of dyes while BAT 40f concerns
only reactive dyes; it seems therefore clearer to keep them separated.
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  No information has been provided about the new generation of dyes which offer the
opportunity  to  wash  off  at  lower  temperature,  with  less  water  and  reduced  washing
off agents.

Technique g.
  It is not clear what changes are proposed by the comment.

Technique h.
  Section 4.5.2.6 of D1 mentions that this technique is not applicable, for example, for
high-grade  dyeing  of  PES/CO  working  clothes,  which  could  usefully  specify  the
applicability restriction.
  Concerning pad-steam dyeing, it is indeed a current process but it is not clear  what
changes are proposed by the comment.
  To extend the relevance of technique a to vat dyes.
  To specify the applicability restriction of technique a.
EIPPCB
  To clarify that technique c is about the use of polyfunctional reactive dyes.
proposal:
  To delete technique d.
  To specify the applicability restriction of technique h.
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Location in
P. 749 – Section 5.5 – BAT 41
D1:
BAT 41. In order to reduce emissions to water from the dyeing of wool, BAT
is to use one of the techniques given below in the following order of priority.

Technique
Description
Applicability
The  applicability
Chromium-free
Wool dyeing is carried out with reactive or  may  be  restricted
a.

dyeing
acid dyes.
by
product
specifications
Dyeing  is  carried  out  with  metal-complex
Current
The  applicability
Optimised
dyes under optimised conditions in terms of
text in D1:
may  be  restricted
b.

metal-complex
pH,  auxiliaries  and  acid  used,  in  order  to  by
product
dyeing
increase the exhaustion of the dyeing liquor  specifications
and the fixation of the dyes.
When  the  use  of  chromates  is  authorised,
chromates  are  dosed  as  a  function  of  the
amount  of  dye  taken  up  by  the  wool.
Minimised  use
Generally
c.

Dyeing
parameters
(e.g.
pH
and
of chromates
applicable
temperature  of  the  dyeing  liquor)  are
optimised  to  ensure  that  the  dyeing  liquor
is exhausted as much as possible.

Technique a.
  Specify and justify the applicability restriction, considering the technical information
given  in  Chapter 4  of  D1  or,  if  not  possible,  delete  the  applicability  restriction
(EEB 100, EEB 113).
  Specify the applicability restriction as follows: “the applicability may be restricted by
product specifications, e.g. where black or very dark shades are essential and cannot
be produced by other reactive or acid dyes.” Indeed chromium-free dyeing should be
widely  practised  by  now  across  the  wool  industry  and  any  continuing  use  should
require detailed justification (UK 43).
  Specify  the  content  below  which  a  dye  would  be  chromium-free  (0.1 %/kg  in  dye)
and  quote  the  relevant  standard  as  chemical  analytical  methods  are  limited  by  their
Summary
limit of detection and limit of quantification (CEFIC 16).
of

comments:
Technique b.
  Change  the  applicability  restriction  to  generally  applicable  because  no  technically
meaningful  explanation  for  possible  restriction  is  given  in  Section 4.5.3.2  of  D1
(EEB 114).

Technique c.
  Delete  technique  c.  because  the  use  of  chromates  is  not  BAT  and  chromates  can
always be substituted (there are chromium-free alternatives for wool and PA dyeing)
(DE 323).
  Replace  “chromates”  with  “dichromates”,  which  is  technically  the  correct  term
(EURATEX 71).
Technique a.
  According  to  Section 4.5.3.1  of  D1,  the  use  of  technique  a  may  be  limited  by  the
required fastness and shade, which could usefully specify the applicability restriction.
  The  BAT  statement  is  clear  about  the  order  of  priority  of  the  three  techniques:
technique a is prioritised over the other two except when product specifications (e.g.
fastness or shade) limit its application.
  The  wording  “chromium-free”  does  not  refer  to  the  absence  of  chromium  as  an
EIPPCB
impurity but to the use of dyes with formulations which are not based on chromium,
assessment:
i.e. not  metal-complex or  do not require chromium  mordant i.e.  chrome dyes.  Some
reactive  dyes  do  not  require  chromium  mordant  as  is  reflected  by  the  description  of
the technique but could be clarified in the technique name.

Technique b.
  Metal-complex  dyes  are  brighter  than  chrome  dyes  but  duller  than  acid  dyes;
therefore  metal-complex  dyes  may  not  be  applicable  when  very  dark  shades  are
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needed.

Technique c.
  Technique  c  is  not  about  the  use  of  dichromates  but  about  the  minimised  use  of
dichromates  when  this  use  has  been  authorised  as  per  Article 60  of  the  REACH
Regulation.
  The  analysis  of  alternatives  to  the  use  of  dichromates  is  part  of  the  authorisation
procedure (see Article 62 of the  REACH  Regulation) and is done on a case-by-case
basis.
  Sodium or potassium dichromate  is  used for chrome  dyeing,  which could be  better
reflected in technique description.
  To specify the applicability restriction of technique a and modify the technique name.
EIPPCB
  To specify the applicability restriction of technique b.
proposal:
  To change the wording of technique c to reflect the use of dichromates.

Location in
P. 749 – Section 5.5 – BAT 42
D1:
BAT 42. In order to reduce emissions to water from the dyeing of polyester
with  disperse  dyes,  BAT  is  to  use  one  or  a  combination  of  the  techniques
given below.

Technique
Description
Applicability
Batch  dyeing  of  polyester  and  wool-free
Batch
dyeing  polyester  blends  is  carried  out  at  high
a.

without  dyestuff  temperature (e.g. 130 ºC) without the use of
carriers
dyestuff carriers.
Generally
Optimised
use
applicable
Batch  dyeing  of  polyester-wool  blends  is
of
dyestuff
b.

carried
out
with
chlorine-free
and
carriers  in  batch  biodegradable dyestuff carriers.
dyeing
The  use  of  a
reducing
agent
Current
that can be used in
text in D1:
This includes:
acidic  conditions
  using a desorption accelerator based on  may
not
be
carboxylic acid derivatives;
applicable
to
Optimised
  using a reducing agent that can be used  polyester-elastane
desorption
of
c.

in  the  acidic  conditions  of  the  spent  blends.
unfixed  dye  in
dyeing liquor;
The  use  of  dyes
batch dyeing
  using  disperse  dyes  that  can  be  desorbable
in
desorbed  in  alkaline  conditions  by  alkaline
hydrolysis instead of reduction.
conditions  may  be
restricted
by
product
specifications
Supercritical  CO2  is  used  as  a  dyeing  Only applicable to
Supercritical
medium  instead  of  water  in  a  closed  loop  new
plants
or
d.

CO2 dyeing
process  to  transport  disperse  dye  into  the  major
plant
polyester fibres.
upgrades

Technique b.
  Mention that technique b. is only relevant for PES-wool blends or alternatively that
the applicability is restricted by product specifications (EURATEX 87).

Technique c.
Summary
  Specify the  wording of the applicability restriction under alkaline conditions in line
of
with the information given in Section 4.5.4.2 of D1, as it is too vague (EEB 115).
comments:
  To improve clarity, make the following changes:
o  change the technique name to: “Optimised reduction of unfixed dye in batch
dyeing”;
o  change first line of description of technique to read: “This includes: using a
reducing agent”;
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o  change  the  last  sentence  of  the  applicability  to  read:  “The  use  of  alkali
reducable  disperse  dyes  may  be  restricted  by  product  specification.”
(UK 44).

Technique d.
  Delete  technique  d.  because  this  technique  is  not  used  in  Europe  (only  one  site  in
Thailand  uses  it).  In  addition,  there  are  concerns  in  terms  of  costs,  security  due  to
high pressure, energy consumption, result of the dyeing process and emissions of CO2
to air (AT 44, FR_A 36, CZ_B 14, EURATEX 125).
Technique b.
  The  relevance  of  technique  to  PES-wool  blends  is  already  mentioned  in  the
description.
  The  name  of  the  technique  could  reflect  the  concern  to  use  the  environmentally
friendly carriers.

Technique c.
  Section 4.4.4.2 of D1 mentions that dyes that are desorbable in alkaline conditions do
not cover all shades and that it may not be applicable for disperse dyes with very high
fastness requirements. This could usefully specify the applicability restriction.
  Technique  c  is  not  only  about  the  reduction  of  unfixed  dye  but  also  about  the
desorption of the dye which can be done without reduction (see the third bullet point).
  The use of reducing agents is mentioned in the second bullet point.

Technique d.
  According  to  Section 2.3.7.2.9  of  the  BREF  Guidance  (Commission  Implementing
EIPPCB
Decision 2012/119/EU), an example plant can be located in the EU or  the rest of the
assessment:
world.  Not  having  an  example  plant  in  the  EU  does  therefore  not  impede  the
derivation  of  BAT.  However,  in  the  present  case,  it  has  limited  the  available
information.
  Concerning  the  costs,  Section 4.5.4.3  of  D1  mentions  lower  operational  costs  than
conventional dyeing but high investment costs. No information is available about the
investment costs.
  Concerning  the  energy  consumption,  Section 4.5.4.3  od  D1  mentions  that  it  is  20-
50 % lower compared to other water-based dyeing.
  No information has been made available about safety issues or  the efficiency of the
CO2-based dyeing process.
  Concerning CO2 emissions, Section 4.5.4.3 of D1 mentions that 5 % of the CO2 is not
recovered and is therefore emitted. This does not bring useful information about the
environmental  impact  of  this  technique  as  it  would  be  necessary  to  compare  these
emissions with the CO2 emitted from the combustion plant which generates heat for a
water-based  process  (and  expressed  for  example  in  kg  of  CO2  per  kg  of  textiles
treated).
  To specify the type of cariers to be used in the name of technique b
  To specify the applicability restriction of technique c.
EIPPCB
  To delete technique d.
proposal:
  To  add  the  research  of  information  about  the  supercritical  CO2  dyeing  in  the
“Recommendations for future work” in Chapter 7 of the BREF.

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1.9
BAT conclusions for finishing

1.9.1
Finishing with flame-retardants

Location in
P. 752– Section 5.7.3 – BAT 49
D1:
BAT 49. In order to improve the overall environmental performance of finishing
with flame retardants, BAT is to use one or both of the techniques given below,
giving priority to technique a.

Technique
Description
Applicability&#